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Country-by-Country Reporting News & Information February 27, 2019

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Issue Number:  2019-1

Inside This Issue

  1. IRS Issues Reminder for U.S. Multinational Enterprises (MNEs) Filing Form 8975 with no U.S. Schedule A (Form 8975)
  2. IRS Issues Reminder for U.S. MNEs of Instructions for Schedule A (Form 8975)
  3. IRS Issues Reminder for U.S. MNEs Filing Form 8975 on Paper
  4. IRS Issues Reminder for U.S. MNEs of Procedures for Amending Form 8975

1.  IRS Issues Reminder for U.S. 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 do 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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2.  IRS Issues Reminder for U.S. MNEs of Instructions for Schedule A (Form 8975)


U.S. MNEs must submit a Schedule A (Form 8975) for each tax jurisdiction in which one or more constituent entities is tax resident. The tax jurisdiction field in Part I of Schedule A is a mandatory field, and U.S. MNEs are required to enter a two-letter code for the tax jurisdiction to which the Schedule A pertains. The country code for the United States is “US” and the country code for “stateless” is “X5.” All other country codes can be found at www.IRS.gov/CountryCodes.

Form 8975 and Schedule A information is exchanged using the OECD Country Code List that is based on the ISO 3166-1 Standard. Although the country codes found in the IRS link above contain the jurisdictions listed in the table below, those jurisdictions do not correspond to a valid OECD country code for purposes of exchanging the information. Therefore, do not enter any of these country codes on the tax jurisdiction line of Part I of Schedule A.

Tax Jurisdiction Country Code
Akrotiri AX
Ashmore and Cartier Islands AT
Clipperton Island IP
Coral Sea Islands CR
Dhekelia DX
Paracel Islands PF
Spratly Islands PG
Other Country OC

If the tax jurisdiction specified in the above list is associated with a larger sovereignty, use the country code for the larger sovereignty with which the tax jurisdiction is associated (e.g., Akrotiri and Dhekelia are considered a British Overseas Territory, so the country code for the United Kingdom would be used (“UK”)). Otherwise, use a separate Schedule A for “stateless” using the tax jurisdiction code “X5”.  In either case, you should include in Part III of Schedule A the name of the specific constituent entity and the jurisdiction where the constituent entity is located.

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3.  IRS Issues Reminder 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. Form 8975 data received on paper must contain appropriate entries as described in the instructions to be converted for electronic exchange.

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. At least one constituent entity must be listed on each Schedule A. Note: If the information entered for a single tax jurisdiction does not fit on a single Schedule A (Form 8975), MNEs can attach additional Schedules A (Form 8975) as follows:
    • Above Part I. Enter the reporting period beginning and ending dates, the name of the reporting entity, and the EIN.
    • Part I. Enter the tax jurisdiction only. Do not complete lines 1 through 8 of Part I.
    • Part II. Complete Part II as needed to list all of the constituent entities resident in the tax jurisdiction.
    • Part III. Enter a statement that indicates this is a continuation sheet, the tax jurisdiction to which the continuation sheet applies, and the page number of the continuation sheets (for example, “Page 3 of 9”). Complete the rest of Part III as necessary.
  • 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.

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 Reminder for U.S. MNEs of Procedures for Amending Form 8975


If a U.S. MNE files Form 8975 and Schedules A (Form 8975) that the MNE later determines should be amended, the MNE must file an amended Form 8975 and all Schedules A (Form 8975), including any that have not been amended, with its amended tax return. The U.S. MNE should use the amended return instructions for the return with which Form 8975 and Schedules A were originally filed and check the amended report checkbox at the top of Form 8975.  Note that the amended return (with the amended Form 8975 and all Schedules A) must be filed using the same method (electronically or by paper) as the original submission.  In other words, if the U.S. MNE is required to e-file an original return and needs to file an amended or superseding return, the amended return must also be e-filed.  Note that for the paper filer, page 1 of the amended Form 8975 should also be mailed to Ogden.

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