If you have additional comments about Country-by-Country Reporting compliance, please send your comments to our email address. Does a check-the-box election have any effect when reporting constituent entities on the CbC Report? Comment on Country-by-Country Reporting § 301.7701-3(b) by making an election (“check-the-box election”). § 301.7701-3(c) allows a business entity that is an eligible entity to be classified for federal tax purposes other than its default classification (partnership, disregarded entity, or corporation) under Treas. If there is more than one constituent entity in a jurisdiction, should the financial information in Part 1 of Schedule A (Form 8975) be reported as an aggregate of the constituent entity information or consist of consolidated data that eliminates intra-jurisdiction transactions between constituent entities in that jurisdiction? The OECD Guidance on the Implementation of Country-by-Country Reporting indicates that, in certain circumstances, jurisdictions may allow MNE groups to provide consolidated data in CbC Reports. MNE group be subject to a local filing requirement in a foreign tax jurisdiction?ĭ12. Under the CbC reporting framework provided by the OECD, under what circumstances would the foreign subsidiaries of a U.S.

MNE group be reported on Form 8975 and Schedule A (Form 8975)?ĭ11. limited partnership (LP) or limited liability company (LLC) that has not elected to be treated as a corporation for federal tax purposes and is the ultimate parent entity of a U.S.

How are U.S limited liability companies (LLCs) reported on Form 8975?ĭ10. multinational enterprise (MNE) needs to modify or correct a submitted Form 8975, can the U.S. MNE group is a specified national security contractor and has already filed Form 8975 and Schedules A (Form 8975) for prior reporting periods, will this information be exchanged in June 2018?ĭ8. MNE provide on Form 8975 and Schedule A (Form 8975)?ĭ7. MNE group is a specified national security contractor, as defined in Notice 2018-31, what information should this U.S. If a taxpayer has already filed its income tax return for the 2016 tax year, but wants to file a Form 8975 for that period (an early reporting period), what should the taxpayer do?ĭ6. Organization for Economic Cooperation and Development (OECD) guidance provides for transitional filing options for multinational enterprise (MNE) groups having an ultimate parent entity in a tax jurisdiction that requires Country-by-Country (CbC) reports for periods that begin after January 1, 2016, or “parent surrogate filing.” Is the United States allowing for this transitional filing?ĭ5. How many Schedules A (Form 8975 should a U.S MNE file?ĭ4. MNE group filed Form 8975 and Schedule A (Form 8975), is it required to mail a copy of page 1 of Form 8975 to the mailbox in Ogden?ĭ3. How do I report instances (or suspicions) of unauthorized disclosure or misuse of information exchanged with a double taxation treaty/tax information exchange agreement partner? Reporting Requirementsĭ2. has a double taxation treaty or tax information exchange agreement in force and a competent authority arrangement operative?Ĭ4. exchange Country-by-Country (CbC) reports with other tax jurisdictions with which the U.S. Which tax jurisdictions does the IRS have competent authority arrangements (CAAs) with for the automatic exchange of CbC reports?Ĭ3. How will the IRS use Country-by-Country (CbC) data?Ĭ2. Where can I find Form 8975 XML schema? Exchange of InformationĬ1. Does the IRS intend to follow the Organisation for Economic Cooperation and Development (OECD) schema as part of electronically filing Form 8975?ī3. Where can I find additional guidance and resources on Country-by-Country (CbC) reporting? Data Format and Structureī1. What is Country-by-Country (CbC) reporting?Ī2.

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