Dissecting the U.S. Treasury’s CbC Reporting Regulations

Expert on in-house corporate tax Nancy Manzano provides World Finance with insight into US country-by-country reporting regulations, with one definitive question in mind, what exactly has changed?

In June 2016, the US Treasury Department (hereafter Treasury) and the Internal Revenue Service (IRS) released the much-anticipated final regulations for country-by-country reporting (CbCR). Since the proposed regulations were released in December 2015, the Treasury has received voluminous comments from taxpayers, coalitions, trade and professional associations, tax advisors, non-governmental organisations, social activist groups and religious organisations. Nonetheless, it is apparent that no substantial changes were made as a result of the comments, even as 2016 drew to a close. All told, the final CbCR regulations are generally consistent with the proposed regulations. And so, what follows is a recap of the changes, non-changes and various clarifications included in the final regulations.

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