On 23 February 2017, the U.S. IRS published draft Instructions for Form 8975 and Schedule A (Form 8975), Country-by-Country Report (CbC Report). A U.S. person must file a CbC Report if it is the ultimate parent entity of a U.S. MNE group with revenues of USD 850 million or more in the immediately preceding reporting period. The first required reporting period for an ultimate parent entity is the 12-month reporting period that begins on or after the first day of a tax year of the ultimate p…