CbC Reporting Final Regulation
IRS issued final regulation related to new country-by-country reporting requirements for ultimate parent entity of a multinational enterprise group (MNE) with revenue of $850M or more. This new filing is required for tax years beginning on or after June 30, 2016. So a calendar year taxpayer would be subject to the filing requirement (Form 8975 – the form is still under development) with its 2017 tax return. This new reporting requirement was implemented to confirm with the rules of the OECD’s action plan on BEPS.
An UME of a US MNE group is defined as a US business entity that controls a group of business entities, at least one of which is organized or tax resident outside of the US, that are required to consolidate their accounts for financial reporting purposes under US GAAP, or that would be required to consolidate their accounts if equity interests in the US business entity were publicly traded on a US security exchange market. The regulation require an MNE group to report on a country-by-county basis income and taxes paid, and the business activity of foreign operations.
Please see the Internal Revenue Bulletin 2016-29 for additional detail.