Share with your friends

Legislative update: Tax committee chairs question country-by-country reporting

Tax committee chairs question cbc reporting

Senate Finance Committee Chairman Orrin Hatch (R-UT) and House Ways and Means Committee Chairman Paul Ryan (R-WI) today sent a letter to Treasury Secretary Jack Lew that outlines their concerns regarding the inclusion on the IRS / Treasury Department’s Priority Guidance Plan of a project to issue regulations relating to country-by-country (CbC) reporting requirements.


Related content

The chairmen of the congressional tax writing committees called on Secretary Lew to respond to their earlier request (June 2015) for information on the base erosion and profit shifting (BEPS) project being developed by the Organisation for Economic Cooperation and Development (OECD).

As reported in a joint release from the Finance and Ways and Means committees, today’s letter from the tax writing committee chairs states, in part:


…we are not convinced that Treasury has the authority to require CbC reporting by certain U.S. companies (including sharing the information with foreign governments). In addition, the benefits to the U.S. government, businesses, and workers from providing sensitive information in the CbC reports (and, just as importantly, the master file document) is unclear, at best. To that end, a request has been made of the Government Accountability Office (GAO) to analyze, among other things, tradeoffs surrounding BEPS recommendations, including CbC reporting and associated possible effects, including costs and risks for U.S. businesses and their workers and effects on the U.S. economy, including employment, investment, and federal revenue.

Rather than expend additional administrative resources on the CbC regulatory project, we encourage Treasury to focus in the near term on preparing and providing the legal memorandum and other documentation requested in our June 9 letter to you. In addition, we ask that Treasury officials consider the results of the GAO analysis of the BEPS project and recommendations before moving forward with any CbC-related guidance.


© 2020 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved.

KPMG International Cooperative (“KPMG International”) is a Swiss entity. Member firms of the KPMG network of independent firms are affiliated with KPMG International. KPMG International provides no client services. No member firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm.

The KPMG logo and name are trademarks of KPMG International. KPMG International is a Swiss cooperative that serves as a coordinating entity for a network of independent member firms. KPMG International provides no audit or other client services. Such services are provided solely by member firms in their respective geographic areas. KPMG International and its member firms are legally distinct and separate entities. They are not and nothing contained herein shall be construed to place these entities in the relationship of parents, subsidiaries, agents, partners, or joint venturers. No member firm has any authority (actual, apparent, implied or otherwise) to obligate or bind KPMG International or any member firm in any manner whatsoever. The information contained in herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 4366, 1801 K Street NW, Washington, DC 20006.

Connect with us


Want to do business with KPMG?


loading image Request for proposal