US Country-By-Country Reporting

The US Treasury and the IRS implemented country­by­country (CbC) reporting requirements to ensure that US multinational enterprises (MNEs) are not subject to CbC filing obligations in multiple foreign tax jurisdictions. US CbC reporting requires the ultimate parent entity to annually file IRS form 8975, "Country­by­Country Report," including schedule A, "Tax Jurisdiction and Constituent Entity Information." The reporting period is for the ultimate parent's annual financial statement that ends with or within its taxable year; if the parent entity does not prepare an annual financial statement, the reporting period is its taxable year.

Regulation section 1.6038­4(h) says that the reporting threshold is US$850 million. That amount is equivalent to the €750 million agreed to on January 1, 2015 under the OECD's BEPS Action 13: Guidance on the Implementation of Transfer Pricing Documentation and Country­by­Country Reporting. The July 18, 2016 Internal Revenue Bulletin