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

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Issue Number:  2018-3

Inside This Issue


  1. IRS Publishes New Content on Country-by-Country (CbC) Reporting
  2. IRS Releases Notification for U.S. Multinational Enterprises (MNEs) Filing Form 8975 with no U.S. Schedule A (Form 8975)
  3. IRS Advises U.S. MNEs of Procedures for Mailing Page 1 of Paper-Filed Form 8975 to the Ogden Mailbox
  4. 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 Releases Notification for U.S. Multinational Enterprises (MNEs) Filing Form 8975 with no U.S. Schedule A (Form 8975)


When submitting Form 8975 and Schedules A (Form 8975), filers must attach at least two Schedules A (Form 8975) to the Form 8975. At least one Schedule A should be for the United States.

A U.S. MNE group with only fiscally transparent United States business entities would not provide a Schedule A for the United States, but would provide a Schedule A for “stateless” entities.

Filers who did not submit either a U.S. or stateless Schedule A (Form 8975) will receive a letter notifying them that an amended return must be filed to ensure their complete and accurate information is exchanged.

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3.  IRS Advises U.S. MNEs of Procedures for Mailing Page 1 of Paper-Filed Form 8975 to the Ogden Mailbox


If a U.S. MNE files Form 8975 and Schedule A (Form 8975) on paper, the MNE should mail a copy of only page 1 of Form 8975 to Ogden to notify the IRS that Form 8975 and Schedules A (Form 8975) have been filed with a paper return.

If a U.S. MNE files Form 8975 and Schedules A (Form 8975) electronically, the filer should not mail a copy of page 1 of Form 8975 to the Ogden mailbox.

See the Instructions for Form 8975 and Schedule A (Form 8975) for further guidance.

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


If a U.S. MNE needs to amend a previously filed Form 8975 and Schedules A (Form 8975), 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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