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Country-by-Country Reporting News & Information January 18, 2018

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Issue Number:  2018-1

Inside This Issue


  1. IRS Publishes New Content on Country-by-Country (CbC) Reporting
  2. IRS Issues Reminders for U.S. MNEs Filing Form 8975 on Paper
  3. IRS Issues Reminders for U.S. MNEs Amending Form 8975

1.  IRS Publishes New Content on Country-by-Country (CbC) Reporting


New content is available on the CbC Reporting pages:

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2.  IRS Issues Reminders for U.S. MNEs Filing Form 8975 on Paper


If a U.S. multinational enterprise (MNE) files Form 8975 and Schedules A (Form 8975) on paper, the filer must follow the instructions carefully. Note that Form 8975 data received on paper must contain appropriate entries as described in the instructions to be converted for electronic exchange.

Please note that when submitting Form 8975 and Schedules A filers must:

  • File a separate Schedule A (Form 8975) for each tax jurisdiction where the MNE group operates and list all of the constituent entities resident in the tax jurisdiction. Note: At least one constituent entity must be listed on each Schedule A.
  • Attach at least two Schedules A (Form 8975) to the Form 8975. In most cases, at least one Schedule A should be for the United States.
  • Enter the tax identification number (TIN), if any, used for each constituent entity. If the constituent entity does not have a TIN, then enter “NOTIN”. Do not leave the TIN field blank.

Also, please note that if you are filing on paper, you should mail a copy of only page 1 of Form 8975 to Ogden to notify the IRS that you have filed Form 8975 and Schedules A (Form 8975) with a paper return. See the Instructions for Form 8975 and Schedule A (Form 8975) for further guidance.

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3.  IRS Issues Reminders for U.S. MNEs Amending Form 8975


If a U.S. MNE files Form 8975 and Schedules A (Form 8975) that it later determines should be amended, file an amended Form 8975 and all Schedules A (Form 8975), including any that have not been amended, with an amended tax return. Use the amended return instructions for the return with which Form 8975 and Schedules A was originally filed and check the amended report checkbox at the top of Form 8975.

Note: In order to ensure the timely automatic exchange of the information on the amended Form 8975 and Schedules A (Form 8975), you should file the amended return and Form 8975 using the same method (electronically or by paper) as the original submission. For example, if the taxpayer is required to e-file an original return and needs to file an amended or superseding return, it must e-file the amended return.

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