James Tobin, a partner with EY's International Tax Services group, recently authored an article published in BNA's Tax Management International Journal discussing the new US regulations on country-by-country (CbC) reporting, finalized on June 29. According to the article, the US reporting requirement will take effect for large multinationals (with over $850 million in revenue) for years beginning on or after June 30, 2016. So for calendar year US parents of multinational groups, the first required filing year in the United States would be 2017. For US parent companies with June 30 fiscal year ends or later, the data would be required for FYE 2017. The due date for filing the information is the same as for filing the company's US federal tax return for the year in question: a maximum of eight-and-a-half months after year end. The author further notes notes that this likely effectively eliminates the use of local financial statements as a potential data source for many multinationals, because many countries do not require filing statutory accounts that quickly.

The article, published in the September 9, 2016, edition of Tax Management International Journal, is attached below.

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ATTACHMENT

Full text of BNA article