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The Internal Revenue Bulletin is the authoritative instrument of the Commissioner of Internal Revenue for announcing official rulings and procedures of the Internal Revenue Service and for publishing Treasury Decisions, Executive Orders, Tax Conventions, legislation, court decisions, and other items of general interest. It is the policy of the Service to publish in the Bulletin all substantive rulings necessary to promote a uniform application of the tax laws, including all rulings that supersede, revoke, modify, or amend any of those previously published in the Bulletin.
These monthly indexes are cumulated on a semiannual basis, and are published in the last Bulletin of each semiannual period.
This document contains final regulations that require annual country-by-country reporting by certain United States persons that are the ultimate parent entity of a multinational enterprise group.
These final regulations provide guidance on the information required to be reported for country-by-country (Cb C) reporting. The last Bulletin for each month includes a cumulative index for the matters published during the preceding months.
Accordingly, the final regulations exclude decedents’ estates, individuals’ bankruptcy estates, and grantor trusts within the meaning of section 671, all the owners of which are individuals, from the definition of business entity. One comment requested that the final regulations clarify whether companies that elect to be treated as domestic corporations under section 953(d) will be treated as U. The preamble to the proposed regulations requested comments on the need for a national security exception for reporting Cb C information and on procedures for a taxpayer to demonstrate that such an exception is warranted. Other comments recommended a bright-line test whereby U. MNE groups that conduct a majority of their business with the U. A business entity that is treated as a partnership in the tax jurisdiction in which it is organized and that does not own or create a permanent establishment in that or another tax jurisdiction generally will have no tax jurisdiction of residence under the definition in proposed § 1.6038–4(b)(6) other than for purposes of determining the ultimate parent entity of a U. The preamble to the proposed regulations indicates that partners of a partnership that is a stateless entity would report their respective shares of the partnership’s items in their respective tax jurisdiction(s) of residence.