Share with your friends

United States: New country-by-country reporting FAQs, filing information

IRS guidance on country-by-country reporting

The IRS this evening issued a release with new country-by-country (CbC) reporting information and providing guidance for U.S. multinational enterprises (MNEs) filing Form 8975, Country-by-Country Report.


Related content

The IRS transmittal message notes that there is new content on CbC reporting (specifically, new "frequently asked questions" (FAQs)).


Other items in the IRS release concern U.S. MNEs filing Form 8975 and Schedule A (Form 8975). The IRS explained:

  • When submitting Form 8975 and Schedules A (Form 8975), filers must attach at least two Schedules A (Form 8975) to the Form 8975. At least one Schedule A must be for the United States.
  • A U.S. MNE group with only fiscally transparent U.S. business entities would not provide a Schedule A for the United States, but would provide a Schedule A for “stateless” entities.
  • Filers that did 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.


Concerning U.S. MNEs that mail page 1 of paper versions of Form 8975 with the Ogden, Utah mailbox, the IRS explained:

  • If a U.S. MNE files Form 8975 and Schedule A (Form 8975) on paper, the MNE is to mail a copy of only page 1 of Form 8975 to Ogden 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 directed not to mail a copy of page 1 of Form 8975 to the Ogden mailbox.


Concerning U.S. MNEs that are amending Form 8975, the IRS guidance provides:

  • If a U.S. MNE needs to amend a previously filed Form 8975 and Schedules A (Form 8975), the taxpayer is directed to file an amended Form 8975 and all Schedules A (Form 8975), including any that have not been amended, with an amended tax return and to use the amended return instructions for the return with which Form 8975 and Schedules A was originally filed and check the amended report checkbox at the top of Form 8975.
  • In order to provide for the timely automatic exchange of the information on the amended Form 8975 and Schedules A (Form 8975), taxpayers are directed to file the amended return and Form 8975 using the same method (electronically or by paper) as the original submission. For example, if the taxpayer is required to e-file an original return and needs to file an amended or superseding return, it must e-file the amended return.

© 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