On 29 June 2016, the U.S. Treasury Department released the final regulations (TD 9773) for the implementation of Country-by-Country (CbC) reporting. Overall, the final regulations generally mirror the proposed regulations released in December 2015 ({News-2015-12-23/P/2- previous coverage}), although certain amendments have been made for clarification.
General Requirements to File CbC Report
The CbC reporting requirements as included in the final regulations apply for U.S. resident ultimate…