Country-by-Country Reporting

26 CFR 1.6038-4, issued under the authority of 26 USC 6001, 6011, 6012, 6031, 6038, and 7805, requires U.S. taxpayers (generally, U.S. business entities with at least $850,000,000 in revenue in the prior reporting period) to furnish certain information with respect to their global operations. Except as provided in 1.6038-4(h), every ultimate parent entity of a U.S. multinational enterprise (MNE) group must make an annual return on Form 8975, Country-by-Country Report, setting forth the information described in paragraph (d) of this section, and any other information required by Form 8975, with respect to the reporting period described in 1.6038-4(c). Form 8975 was developed to provide certain information required to report annual country-by-country reporting by certain United States persons that are the ultimate parent entity of a US MNE that has annual revenue for the preceding annual accounting period of $850 million or more. Separate Schedule A's (Form 8975) are to be filed for each tax jurisdiction in which a group has one or more constituent entities resident.

The latest form for Country-by-Country Reporting expires 2023-03-31 and can be found here.