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Form 8975: Country-by-Country Report
IRS Form 8975 is the Country-by-Country Report, used to annually report certain information for U.S. multinational enterprises (U.S. MNE) groups that have annual revenue of $850 million or more.
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IRS Form 8975 - Country-by-Country Report
IRS Form 8975 is the Country-by-Country Report, used to annually report certain information for U.S. multinational enterprises (U.S. MNE) groups that have annual revenue of $850 million or more.
Risk Radar
Scan points- 1Ensure every tax jurisdiction has a corresponding entry—either a U.S. Schedule A or a 'stateless' one for fiscally transparent entities.
- 2Omitting a required Schedule A (Form 8975) for a tax jurisdiction where constituent entities are resident.
- 3Failing to list fiscally transparent U.S. business entities on a 'stateless' Schedule A (Form 8975).
- 4Not providing aggregate financial amounts and employee counts in Part I for each tax jurisdiction.
- 5Using the wrong code ('OC') when filing a separate Schedule A (Form 8975) for an "other country."
Plain English
This form requires large U.S. companies operating internationally to detail where their money and employees are located across various countries. It provides the IRS with a snapshot of the company's global business activities for each reporting period. This helps the government ensure that profits are taxed in the correct jurisdictions.
Submission Date
- Filing date: 2020-12-18 22:10:57
- Preparation window: collect IDs, supporting records, and signatures in advance.
- Final review: verify names, dates, and required fields before submission.
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What this form is for
- Use this form when a U.S. person is the ultimate parent entity of a U.S. multinational enterprise (U.S. MNE) group with annual revenue of $850 million or more for the preceding reporting period.
- Do not use Form 8975 if the annual revenue of your group for the immediately preceding reporting period was less than $850 million.
- Check Schedule A (Form 8975) instead when providing additional information related to the U.S. MNE group.
Form selector
Use this form or another form?
Filing Form 1120, 1065, or 1120-S
Must attach Form 8975 and Schedules A to these returns when filing electronically.
✓ Check the attachment requirements for your specific return.
Filing Form 990-T electronically
Can be filed electronically beginning January 2021, encouraging timely automatic exchange of information.
✓ Ensure the electronic format is correct, not a binary attachment.
Filing Forms 1120-C, 1120-L, 1120-PC, or 1120-RIC (Paper)
These filers should use the mailing addresses provided for their applicable income tax return.
✓ Verify the specific mailing address listed on your paper return.
Filing Form 1041 electronically
Must attach Form 8975 and Schedules A electronically in the correct format, not as a binary attachment.
✓ Confirm that you are filing electronically to ensure timely automatic exchange.
Deadline or filing window
The Form 8975 must be attached to the income tax return and filed by that return’s due date, including any extensions granted. To request an extension, follow the instructions of the specific income tax return to which Form 8975 will be attached.
Checklist
What you need before filling it out
Reporting entity name
Name of the reporting entity (1a) · Part I
Annual Revenue Threshold
$850 million or more · General Instructions/Who Must File
Filing Deadline
Due date of the income tax return (including extensions) · When To File
Paper Filing Address
Internal Revenue Service Mailstop 4950, 1973 N. Rulon White Blvd., Ogden, UT 84201 · Where To File
Penalties for Failure to File
Penalties under section 6038(b) · Record Maintenance
U.S. MNE Group Definition
U.S. multinational enterprise (U.S. MNE) group · General Instructions/Who Must File
Before you submit
- 1Verify that the reporting period dates are correctly entered on Form 8975.
- 2Confirm the name and EIN of the reporting entity in Part I.
- 3Check the box if you are filing an amended report.
- 4Enter the correct number of Schedules A (Form 8975) attached to this Form 8975.
- 5If applicable, ensure all required fields for the U.S. MNE group name and role code are filled out.
- 6If mailing a paper return, confirm you have included a copy of page 1 with the submission.
- 7Ensure that if filing electronically, Form 8975 is attached in the correct format (not as a binary attachment).
How to file this form
- 1Complete Part I by entering your entity's name, role code, EIN, and address details on Form 8975.
- 2Fill out any additional information related to the U.S. MNE group in Part II of Form 8975.
- 3Attach all necessary Schedules A (Form 8975) to this main Form 8975 document.
- 4File the completed Form 8975 and attached Schedules A by the due date of your income tax return.
Known limitations
- 1A U.S. MNE group does not need to file Form 8975 if its annual revenue for the immediately preceding reporting period was less than $850 million.
- 2Part II of Form 8975 is optional to complete.
- 3Fiscally transparent U.S. business entities do not have a tax jurisdiction of residence for reporting purposes on Form 8975.
- 4If a filer lacks either a U.S. Schedule A (Form 8975) or a 'stateless' Schedule A (Form 8975) containing fiscally transparent U.S. business entities, the Form 8975 is not completed properly.
Field map
Compact field-by-field guide
Entity Info
1 items
Name and taxpayer ID of the entity claiming the credit.
Credit Info
1 items
Type of credit or incentive being claimed.
Calculation
2 items
The base amount used to calculate the credit.
Calculated credit amount after applying formulas and limitations.
Certification
1 items
Detailed breakdown supporting the credit calculation.
Signatures
1 items
Sign and date the form.
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Fillable formOpen in Editor->The current edition is December 2020, and filers can find the latest information regarding Form 8975 at IRS.gov/Form8975.
What changed or needs a fresh check
- Edition date — confirm the revision date reads December 2020.
- Filer identification (Part I) — confirm you have entered your name, EIN, and reporting role code.
- Mailing address — for paper filing, mail to Internal Revenue Service Mailstop 4950, 1973 N. Rulon White Blvd., Ogden, UT 84201.
- Amended report flag — check the box if you are submitting an amended report.
- Schedules A count — enter the correct number of Schedules A (Form 8975) attached to Form 8975.
Quick Facts
Downloads
After you file
- 1Keep a copy of the filed Form 8975 and Schedules A (Form 8975).
- 2Attach Form 8975 and Schedules A (Form 8975) to the income tax return of the ultimate parent entity of the U.S. MNE group for the tax year in or within which the reporting period ends.
- 3If filing electronically, ensure the amended report checkbox is checked on Form 8975 when amending a previously filed report.
- 4When filing an amended return, use the amended return instructions corresponding to the original return with which Form 8975 and Schedules A (Form 8975) were attached.
Sources
- SRCInstructions p.1 — Certain U.S. persons that are the ultimate parent entity of a U.S. MNE group with annual revenue for the preceding reporting period of $850 million or more are required to file Form 8975.
- SRCInstructions p.1 — The filer must list the constituent entities, indicating tax jurisdiction (if any), country of organization and main business activity, and provide financial and employee information for each tax jurisdiction where the U.S. MNE does business.
- SRCInstructions p.2 — Form 8975 and Schedules A (Form 8975) must be filed with the IRS by the due date (including extensions) for the income tax return of the ultimate parent entity.
- SRCInstructions p.3 — At least one Schedule A (Form 8975) must be attached for each tax jurisdiction in which the group operates, including the United States.
- SRCInstructions p.4 — The country code for the United States is 'US' and the country code for 'stateless' is 'X5' on Schedule A (Form 8975).
- SRCInstructions p.1 — Form 8975 and Schedules A (Form 8975) must be filed with the IRS along with the income tax return of the ultimate parent entity.
- SRCInstructions p.2 — The required forms for attachment include Forms 1120, 1120-C, 1120-RIC, 1065, 1120-S, 1120-L, 1120-PC, 1120-REIT, 990-T, and 1041.
Common confusion points
Who must file this form?
Certain U.S. persons that are the ultimate parent entity of a U.S. multinational enterprise (U.S. MNE) group with annual revenue for the preceding reporting period of $850 million or more must file Form 8975.
How many Schedules A do I need to file?
The filer must attach at least one Schedule A (Form 8975) for each tax jurisdiction in which the U.S. MNE group operates, meaning a minimum of two schedules are filed (one generally for the U.S.).
What code should I use for the United States?
The two-letter code for the United States is 'US' on Schedule A (Form 8975).
What code do I use if my entity has no tax jurisdiction of residence?
The country code for 'stateless' is 'X5' on Schedule A (Form 8975).
Where does the filing deadline come from?
Form 8975 and Schedules A (Form 8975) must be filed with the income tax return of the ultimate parent entity, adhering to that return's due date (including extensions).
Does this form replace my income tax return?
No; it is attached to the income tax return (e.g., Form 1120), not filed separately.
Workflow map
Related forms and next steps
Before
Current
After
Often used with
⚠ If something goes wrong
- Use the amended return instructions for the return with which you originally filed Form 8975 and Schedules A (Form 8975) when filing an amendment.
Questions about IRS Form 8975
What is IRS Form 8975 used for?
This form requires large U.S. companies operating internationally to detail where their money and employees are located across various countries. It provides the IRS with a snapshot of the company's global business activities for each reporting period. This helps the government ensure that profits are taxed in the correct jurisdictions.
Who must file IRS Form 8975?
Certain U.S. persons who are the ultimate parent entity of a U.S. multinational enterprise (U.S. MNE) group must file Form 8975 and its Schedules A (Form 8975). Filing is required if the annual revenue for the preceding reporting period was $850 million or more.
What information does IRS Form 8975 require?
Part I collects the filer's identifying information, such as their complete legal name. Part II allows entry of additional narrative information about the group's operations. Each Schedule A (Form 8975) details financial amounts and employee numbers for a specific tax jurisdiction.
When is IRS Form 8975 due?
The Form 8975 must be attached to your income tax return and filed with the IRS by the due date (including extensions) for that income tax return. An extension of time can be requested by following the instructions for the associated income tax return.
Where do I file IRS Form 8975?
Most filers will electronically file their country-by-country reports. If filing on paper, mail a copy of page 1 of Form 8975 to the IRS using the mailing addresses provided for the applicable income tax return.
How do I complete IRS Form 8975?
First, complete Part I with your identifying details. Next, use Part II for any narrative description of your business structure or conventions. Finally, provide detailed financial data on each Schedule A (Form 8975), ensuring you list all constituent entities resident in that jurisdiction.
What happens if IRS Form 8975 is filed incorrectly?
The instructions do not specify a penalty amount, but failing to complete the form properly suggests an error in reporting information with respect to the filer’s U.S. group activities.
Who must file this form?
Certain U.S. persons that are the ultimate parent entity of a U.S. multinational enterprise (U.S. MNE) group with annual revenue for the preceding reporting period of $850 million or more must file Form 8975.
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