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Tax Alert: IRS Proposes Country-by-Country Reporting Rules for 2017

Dec 22, 2015

The IRS released proposed rules this week that would require country-by-country reporting for companies with U.S. parents and annual revenue of $850 million or more. The information to be reported ((REG-109822-15, RIN 1545-BM70) would include the amount of revenue, profit or loss, capital and accumulated earnings for each country of operation and are consistent with OECD recommendations designed to combat base erosion and profit shifting. These new rules most likely wouldn’t take effect until after January 1, 2017.

The IRS has asked for feedback from federal agencies like the Department of Defense to determine if there are national security implications from these country-by-country reporting requirements. In addition, the IRS is seeking comments on determining which entities qualify as U.S. parent organizations and would need to follow these rules.

To learn more about the proposal, please refer to

If you have any questions, please contact WTP’s National Transfer Pricing and Valuation Services Practice leader, Guy Sanschagrin at

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