Annual Report Requirements for Multinational Companies
Added to the already overwhelming various international information disclosure requirements, the IRS issued final regulations requiring large US multinational companies to file annual report disclosing certain information on a country-by-country basis related to their income and tax payments. The regulations are issued in connection with the BEPS implementation by the US government.
Generally, the filing requirement apply to US taxpayers that are the ultimate parent entities of multinational enterprise group with prior year annual revenue in excess of $850 million. The regulations are effective tax years beginning on or after July 1, 2016.
Click below link to see a copy of 1.6838-4 for your reference.