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ARTICLE · 21 JULY 2016

IRS Issues Final Regs On BEPS Country-By-Country Reporting

The IRS issued final regulations on June 29 that will require U.S. multinationals with more than $850 million in revenue to report specific information on a country-by-country basis for the first time.

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The IRS issued final regulations ( TD 9773) on June 29 that will require U.S. multinationals with more than $850 million in revenue to report specific information on a country-by-country basis for the first time.

The regulations were drafted to comply with new country-by-country reporting (CbCR) standards created by the base erosion and  the Organisation for Economic Co-operation and Development's (OECD's) base erosion and profit shifting project.

The new reporting will be performed on Form 8975, Country-by-Country Report, and applies to "multination enterprise groups" with a U.S. parent (U.S. MNEs) that have annual revenue for the preceding annual accounting period of 850 million USD or more. Form 8975 will require, on a jurisdictional basis, information on a U.S. MNE group's revenues, taxes paid, number of employees, functions performed and certain other indicators of profit allocation within the group.

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