According to recent reports, the U.S. Treasury is currently planning to introduce a filing requirement for large U.S. based multinationals in line with the country-by-country (CbC) reporting requirements introduced by the OECD as part of its Base Erosion and Profit Shifting (BEPS) Project. Based on the recently issued OECD guidelines concerning country-by-country reporting, the first report should be filed for fiscal years beginning on or after 1 January 2016, and it is expected that the U.S.…