The Treasury Department and IRS late this afternoon released for publication in the Federal Register proposed regulations (REG-109822-15) that would require annual country-by-country by U.S. persons that are the ultimate parent entity of a multinational enterprise (MNE) group.
The proposed regulations would apply for U.S. persons that are the ultimate parent entity of a MNE group that has annual revenue for the preceding annual accounting period of $850 million or more.
Read text of the proposed regulations [PDF 252 KB] on country-by-country (CbC) reporting. These regulations are scheduled to be published in the Federal Register on December 23, 2015.
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