Printable Form 2026

IRS Form 8975 (Schedule A)

IRS Form 8975 (Schedule A) – If your U.S.-based multinational enterprise (MNE) group exceeds $850 million in annual revenue, you likely need to file IRS Form 8975, the official Country-by-Country Report. This form promotes tax transparency under OECD BEPS Action 13 and helps tax authorities assess transfer pricing risks and base erosion.

This comprehensive guide (updated for 2026) covers who must file, what information to report, deadlines, step-by-step completion instructions, penalties, and official IRS resources. All details come directly from IRS.gov, including the latest Form 8975 (Rev. December 2020), Schedule A, and instructions.

What Is IRS Form 8975 and Why Does It Matter?

Form 8975, Country-by-Country Report, requires ultimate parent entities of U.S. MNE groups to report aggregated financial and tax data by tax jurisdiction. It includes revenues, profits, taxes paid/accrued, employees, and tangible assets—plus a list of constituent entities per jurisdiction.

The IRS uses this data (along with foreign partners via automatic exchange under competent authority arrangements) for high-level risk assessments. It does not replace regular tax returns or serve as direct audit evidence, per OECD guidance incorporated in U.S. Treasury Regulations §1.6038-4.

Key purpose (verbatim from IRS instructions): “To annually report certain information with respect to the filer’s U.S. MNE group on a country-by-country basis.”

U.S. implementation began for reporting periods starting on or after June 30, 2016. The form remains unchanged as of 2026 (Rev. December 2020), with no recent developments noted on the official About Form 8975 page (last reviewed January 23, 2026).

Download the official PDF here: IRS Form 8975 PDF

Who Must File IRS Form 8975?

You must file if all these conditions apply:

  • You are a U.S. person (or U.S. territory ultimate parent entity designating a U.S. business entity).
  • You are the ultimate parent entity of a U.S. MNE group.
  • The group’s annual revenue in the immediately preceding reporting period was $850 million or more (U.S. dollars, per applicable financial statements or tax year if none).

Definitions (from IRS Instructions for Form 8975):

  • Ultimate parent entity: A U.S. business entity that owns (directly/indirectly) other entities requiring consolidation under U.S. GAAP (or would if publicly traded) and is not itself consolidated by another entity.
  • U.S. MNE group: The ultimate parent + all consolidated business entities (including disregarded entities and permanent establishments with separate financials).
  • Constituent entity: Separate business entities in the group (with specific exclusions for certain foreign entities).

Exceptions:

  • Revenue below $850 million in the prior period → No filing required.
  • Non-U.S. parented groups generally do not file with IRS (local filing may apply elsewhere).

Special rules exist for U.S. territory parents and “specified national security contractors” (see Notice 2018-31 for simplified reporting with aggregated U.S. data only).

Reporting Period and Filing Deadlines

The reporting period is typically the 12-month period of your applicable financial statement (AFS) ending with or within your tax year. If no AFS, use your tax year-end.

Filing rules:

  • Attach Form 8975 + all required Schedule A to the ultimate parent entity’s income tax return (e.g., Form 1120, 1065, 1120-S, 990-T, 1041, etc.).
  • File by the due date of that return, including extensions.
  • Cannot file standalone.
  • Electronic filing (MeF XML format) is strongly encouraged for timely international exchange; paper filers must mail Page 1 of Form 8975 to IRS Ogden for processing.

Amended reports: File a full amended Form 8975 + all Schedules A with an amended return. Check the “amended report” box.

Early/surrogate filing was allowed under Revenue Procedure 2017-23 for pre-2017 periods.

How to Complete Form 8975 and Schedule A (Step-by-Step)?

Form 8975 (one per group):

  • Reporting period dates.
  • Amended report checkbox.
  • Number of Schedule A attached.
  • Part I – Identification of Filer: Name, reporting role code, EIN, address, and MNE group name (if different).
  • Part II – Additional Information: Any explanatory notes.

Schedule A (Form 8975) – One per tax jurisdiction (including United States and “Stateless” for certain U.S. LLCs):

  • Part I – Tax Jurisdiction Information (all amounts in U.S. dollars):
    • Revenues: Unrelated party / Related party / Total
    • Profit (loss) before income tax
    • Income tax paid (cash basis)
    • Income tax accrued – current year
    • Stated capital
    • Accumulated earnings
    • Number of employees
    • Tangible assets other than cash & cash equivalents: Unrelated / Related / Total
  • Part II – Constituent Entity Information:
    • List each resident constituent entity.
    • Entity role, TIN, tax jurisdiction of organization (if different), main business activity code (or description if “Other”).
  • Part III – Additional Information (optional explanatory notes).

Minimum attachments: At least two Schedules A—one for the United States (aggregated data) and one for each other jurisdiction. Stateless entities get their own Schedule A.

Recordkeeping: Maintain supporting records, but no reconciliation to tax returns or AFS is required.

Special cases:

  • Specified national security contractors: Simplified U.S.-only + Stateless Schedules A.
  • U.S. LLCs (disregarded): Often reported as “stateless.”

Penalties for Non-Compliance

Failure to file or provide complete information can trigger penalties under IRC Section 6038(b). General accuracy-related penalties may also apply. Timely electronic filing helps avoid delays in international exchanges.

Benefits of Proper CbC Reporting

  • Demonstrates compliance and transparency.
  • Reduces risk of local filing obligations in foreign jurisdictions via surrogate filing.
  • Supports IRS high-level risk assessments without direct audit use.
  • Data is exchanged automatically only with jurisdictions having operative competent authority arrangements (see IRS Jurisdiction Status Table).

Common Mistakes to Avoid

  • Filing as standalone (must attach to return).
  • Submitting incomplete Schedules A (must cover every jurisdiction + U.S./Stateless).
  • Using wrong format for e-filing (XML only, no PDF/binary).
  • Forgetting to mail Page 1 for paper returns.
  • Not amending the full set of Schedules A when corrections are needed.

Official Resources and Downloads (2026)

For the absolute latest updates, always check IRS.gov/Form8975.

Need help? Consult a qualified tax professional familiar with international reporting and U.S. GAAP consolidation rules. Proper preparation of IRS Form 8975 protects your organization and supports global tax compliance.

This guide is for informational purposes only and is not tax or legal advice. Requirements can depend on specific facts—refer to official IRS instructions and regulations.