In December, the I.R.S. released Prop. Treas. Reg. §1.60384 -15, which details the country-by-country (CbC) reporting that will be required of large U.S.-based business entities. The proposed regulations define the persons required to file the CbC report, companies that are to included in the report, information that must be reported, acceptable measurement methodologies to be used, and uses to which data may be put.
These regulations closely follow the model recommended by the O.E.C.D. B.E.P.S. report. Sheryl Shah and Stanley C. Ruchelman explain the I.R.S.’s reasons and request for input regarding national security exemptions not otherwise considered by the O.E.C.D. See more →