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Regulatory Transition Issue Addressed in Country-by-Country Reporting

Michael Mundaca serves as the co-director of Americas Tax Center and the National Tax Department at Ernst & Young (EY). A former assistant secretary for tax policy at the US Treasury Department, Michael Mundaca facilitates tax services for a wide range of clients.

A recent EY Americas Tax Center report drew attention to the Internal Revenue Service’s June 30, 2017, launch of detailed website information on country-by-country (CbC) reporting. Under US Treasury regulations, US multinationals’ parent entities with revenues equal to or exceeding $850 million must file Form 8975 to report a US multinational group’s income, taxes paid, and other indicators of economic activity on a country-by-country basis starting for the US multinational group’s first reporting period in the tax year that starts on or after June 30, 2016.

The EY Global Tax Alert brings to light a situation in which there is potential for duplicative CbC reporting requirements for US multinational groups operating in foreign jurisdictions, although the IRS and the US Treasury have announced they will allow the voluntary filing of CbC reports to address this situation.

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