On Thursday, January 19, the IRS released Revenue Procedure 2017-23 which allows for early filing of Country-by-Country Reports (Form 8975). As background, in June 2016, the U.S. Treasury issued regulations requiring large, U.S.-based multinationals to file a report detailing income, taxes paid, headcount, and other key business metrics on a country-by-country basis. These U.S. regulations apply to companies with reporting periods that begin on or after June 30, 2016. However, many foreign jurisdictions have implemented country-by-country reporting rules with an effective date of January 1, 2016. As a result, U.S.-based multinationals with operations in jurisdictions with an earlier effective date are faced with a timing gap in global filing requirements. Thursday's revenue procedure addresses this timing gap by allowing U.S.-based multinationals to file Country-by-Country Reports with the IRS for periods prior to June 30, 2016, including situations where the taxpayer has already filed their U.S. tax return.

The IRS will begin accepting early filings September 1, 2017 and is encouraging taxpayers to file electronically to ensure timely exchange of information with foreign jurisdictions. The IRS has also indicated its intention to issue detailed electronic filing instructions in early 2017.

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