US country-by-country reporting guidance | KPMG | GLOBAL

United States: New country-by-country reporting FAQs, filing information

IRS guidance on country-by-country reporting

The IRS this evening issued a release with new country-by-country (CbC) reporting information and providing guidance for U.S. multinational enterprises (MNEs) filing Form 8975, Country-by-Country Report.

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The IRS transmittal message notes that there is new content on CbC reporting (specifically, new "frequently asked questions" (FAQs)).

 

Other items in the IRS release concern U.S. MNEs filing Form 8975 and Schedule A (Form 8975). The IRS explained:

  • When submitting Form 8975 and Schedules A (Form 8975), filers must attach at least two Schedules A (Form 8975) to the Form 8975. At least one Schedule A must be for the United States.
  • A U.S. MNE group with only fiscally transparent U.S. business entities would not provide a Schedule A for the United States, but would provide a Schedule A for “stateless” entities.
  • Filers that did not submit either a U.S. or stateless Schedule A (Form 8975) will receive a letter notifying them that an amended return must be filed to ensure their complete and accurate information is exchanged.

 

Concerning U.S. MNEs that mail page 1 of paper versions of Form 8975 with the Ogden, Utah mailbox, the IRS explained:

  • If a U.S. MNE files Form 8975 and Schedule A (Form 8975) on paper, the MNE is to mail a copy of only page 1 of Form 8975 to Ogden to notify the IRS that Form 8975 and Schedules A (Form 8975) have been filed with a paper return.
  • If a U.S. MNE files Form 8975 and Schedules A (Form 8975) electronically, the filer is directed not to mail a copy of page 1 of Form 8975 to the Ogden mailbox.

 

Concerning U.S. MNEs that are amending Form 8975, the IRS guidance provides:

  • If a U.S. MNE needs to amend a previously filed Form 8975 and Schedules A (Form 8975), the taxpayer is directed to file an amended Form 8975 and all Schedules A (Form 8975), including any that have not been amended, with an amended tax return and to use the amended return instructions for the return with which Form 8975 and Schedules A was originally filed and check the amended report checkbox at the top of Form 8975.
  • In order to provide for the timely automatic exchange of the information on the amended Form 8975 and Schedules A (Form 8975), taxpayers are directed to file the amended return and Form 8975 using the same method (electronically or by paper) as the original submission. For example, if the taxpayer is required to e-file an original return and needs to file an amended or superseding return, it must e-file the amended return.

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