Treasury Works to Smooth Country-by-Country Reporting Gap

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Jan. 14 — The Treasury Department said it is “exploring discussions” with foreign jurisdictions to ease any administrative hassles or privacy concerns due to a one-year delay in the implementation of U.S. country-by-country reporting requirements.

“We are fully aware of the issue and are exploring discussions with other countries, among other avenues, to assure that country-by-country gets off to a smooth start for everyone—companies and tax administrations alike,” a Treasury spokesman told Bloomberg BNA Jan. 14.

The IRS issued the proposed regulations Dec. 18, but they won't take effect until the taxable year after they are finalized—for most companies, likely to be Jan. 1, 2017.

Some practitioners have raised concerns that companies will still have to file in local jurisdictions for 2016, without the privacy protections of treaty-based information exchange networks and new administrative headaches for the one-year gap (09 DTR G-5, 1/14/16).

The regulations, requiring companies to submit a full global blueprint of their operations, are part of the OECD's action plan on base erosion and profit shifting, which was finalized in October. Many countries have already enacted them into law, or have proposed or indicated rules to do so.

To contact the reporter on this story: Alex M. Parker in Washington at
To contact the editor responsible for this story: Molly Moses at