Issue Number: 2019-2
Inside This Issue
- IRS Issues Updates for Form 8975 Instructions
- IRS Updates Mailstop for U.S. MNEs Filing Form 8975 on Paper
- IRS Updates Guidance on “Stateless” Country Code and Tax Jurisdiction Table for Schedule A (Form 8975)
1. IRS Issues Updates for Form 8975 Instructions
The IRS updated instructions for filing Form 8975. The updated instructions were published on www.IRS.gov July 1, 2019. Key changes are highlighted in items 2 & 3 below.
See the Instructions for Form 8975 and Schedule A (Form 8975) for further guidance.
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2. IRS Updates Mailstop 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. The Form 8975 and Schedules A (Form 8975) must be attached to the applicable paper tax return. Form 8975 filers should use the mailing address provided below for the applicable income tax return:
Internal Revenue Service
Mailstop 4950
1973 N. Rulon White Blvd.
Ogden, UT 84201
See the Instructions for Form 8975 and Schedule A (Form 8975) for further guidance.
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3. IRS Updates Guidance on “Stateless” Country Code and Tax Jurisdiction Table 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 |
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 “other country” using the tax jurisdiction code “OC”. 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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