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US country by country reporting regulations

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The US Internal Revenue Service (IRS) has issued final regulations requiring annual country by country (CbC) reporting by the ultimate parent entities of US multinational groups that have annual revenues of $850m or more in their preceding annual accounting periods (see

The Treasury Department and IRS have confirmed that they will allow US groups to file CbC reports on a voluntary basis for periods beginning on or after 1 January 2016, i.e. before the applicability date of the final regulations (30 June 2016). This is to avoid possible multiple filing obligations arising from the introduction of CbC reporting from 1 January 2016 under the OECD’s BEPS rules.

Issue: 1316
Categories: News