The IRS intends to amend the Regs.Sec.1.6038-4 country by country (CbC) reporting obligations for US multinational enterprise (MNE) groups that qualify as a "specified national security contractor". The amended reporting obligations will limit the information required to be provided in Schedule A of Form 8975, Country by Country Report, so that all financial and employee information will be aggregated and reported only in the US. Additionally, only zeroes would be reported for financial and employee information in the "Stateless" jurisdiction.
Taxpayers meeting the definition of specified national security contractor who already have filed Form 8975 and Schedules A may amend those filings to be consistent with the treatment provided in the Notice, but must do so by 20 April 2018 (or 25 May 2018 if filing electronically).
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