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Country-by-Country Reporting News & Information April 10, 2018

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Issue Number:  2018-2

Inside This Issue


  1. IRS Publishes New Content on Country-by-Country (CbC) Reporting
  2. IRS Releases Guidance for Specified National Security Contractors Filing Form 8975 and Schedules A (Form 8975)
  3. IRS Issues Reminders for Paper Filers of Form 8975 that Received Letters Requesting Amended Filings

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 Releases Guidance for Specified National Security Contractors Filing Form 8975 and Schedules A (Form 8975)


The Office of Associate Chief Counsel (International) has released Notice 2018-31 providing new guidance for U.S. MNEs that are specified national security contractors, as defined in the notice, filing Form 8975. The notice can be found here.

Specified national security contractors that wish to file amended CbC reports to supersede an already-filed Form 8975 and Schedules A (Form 8975) should do so by April 20, 2018, for paper filers, and May 25, 2018, for electronic filers, in order to ensure an originally-filed Form 8975 and Schedules A (Form 8975) are not automatically exchanged.

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3.  IRS Issues Reminders for Paper Filers of Form 8975 that Received Letters Requesting Amended Filings


Paper filers of Form 8975 and Schedule A (Form 8975) that receive letters from the IRS notifying them of errors with their filing are urged to submit an amended return by April 20, 2018 to ensure their CbC reports are exchanged in June.

U.S. MNEs should file an amended tax return following the instructions for filing amended tax returns with the amended report checkbox marked. Paper filers should also mail a copy of page 1 of their amended Form 8975 to Ogden as provided in the Instructions for Form 8975 and Schedule A (Form 8975) under the heading “Where to File.”

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