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United States: IRS reminders relating to Form 8975 “Country-by-Country Report”

United States: IRS reminders relating to Form 8975

The IRS today issued a release that includes reminders for multinational entity (MNE) groups on the processes for filing country-by-country reports on Form 8975.

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As noted in the IRS transmittal message:

  • MNEs filing Form 8975, Country-by-Country Report, and Schedules A (Form 8975), Tax Jurisdiction and Constituent Entity Information, must attach at least two Schedules A (Form 8975) to the Form 8975. At least one Schedule A is 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 that 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.
  • U.S. MNEs must submit a Schedule A (Form 8975) for each tax jurisdiction in which one or more constituent entities are 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 on the IRS website 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. Not all country codes found on the IRS website correspond to a valid OECD country code for purposes of exchanging the information. 
  • If a U.S. MNE files Form 8975 and Schedules A (Form 8975) on paper, the MNE is instructed to mail a copy of only page 1 of Form 8975 to the IRS Service Center in Ogden, Utah, 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 is not to mail a copy of page 1 of Form 8975 to the Ogden mailbox.
  • If a U.S. MNE files Form 8975 and Schedules A (Form 8975) that the MNE later determines need to 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 is to 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.  
  • 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. 

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