On June 30, 2016 the Final Regulations regarding Country-by-Country (CbC) Reporting as issued by the U.S. Department of the Treasury/IRS were published in the Federal Register/Volume 81, No. 126/Thursday, June 30, 2016. The regulations are effective June 30, 2016.
The document contains final regulations that require annual country-by-country reporting by certain United States persons that are the ultimate parent entity of a multinational enterprise group. The final regulations affect United States persons that are the ultimate parent entity of a multinational enterprise group that has annual revenue for the preceding annual accounting period of $850,000,000 or more.
The document contains amendments to 26 CFR part 1. Furthermore it also contains a section titled: “Summary of Comments and Explanation of Revisions”, in which a.o. the following subjects are discussed:
· United States Participation in CbC Reporting
· Form 8975, Country-by-Country Report
· Constituent Entities and Persons Required To File Form 8975
o Variable Interest Entities
o Permanent Establishments
o Grantor Trusts and Decedents’ Estates
o Deemed Domestic Corporations
· National Security Exception
· Partnerships and Stateless Entities
· Clarification of Terms
· Other Form or Information Modifications
· Voluntary Filing Before the Applicability Date
· Time and Manner of Filing
· Employees
· Source of Data and Reconciliation
· Expanding Scope and Surrogate Parent Entity Filing
· Tax Jurisdiction of Residence and Fiscal Autonomy
· Reporting Threshold
· Confidentiality and Use of the CbCR
· Exchange of Information With Foreign Jurisdictions
· Penalties
Click here to be forwarded to the Final Regulations regarding Country-by-Country (CbC) Reporting as in the Federal Register on June 30, 2016.
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