IRS Publication 5654 – IRS Forms, Instructions, Pubs 2026

IRS Publication 5654 – IRS Forms, Instructions, Pubs 2026 – In today’s global tax environment, transparency is more important than ever. IRS Publication 5654 (revised December 2025) delivers a concise, authoritative summary of aggregated data from Country-by-Country (CbC) Reports filed by U.S. multinational enterprises (MNEs) for Tax Year 2022.

This Statistics of Income (SOI) one-sheet publication, officially titled Country-by-Country Report, Tax Year 2022, highlights key statistics from Form 8975 filings. It serves as an essential resource for tax professionals, corporate tax teams, policymakers, researchers, and anyone tracking international tax compliance and BEPS (Base Erosion and Profit Shifting) developments.

What Is Country-by-Country (CbC) Reporting?

The OECD developed CbC reporting as part of Action 13 of its BEPS project to give tax administrations a high-level view of MNE operations, including where profits are reported, taxes are paid, and economic activity occurs.

In the United States, the IRS requires certain large U.S. MNE groups to file annual CbC reports. These reports are exchanged automatically with partner jurisdictions under competent authority agreements, promoting greater transparency while protecting taxpayer confidentiality.

Publication 5654 presents aggregated, anonymized statistics derived from these filings, helping the public and stakeholders understand patterns in global profit allocation, tax payments, and business activities of U.S.-parented MNEs.

Who Must File a Country-by-Country Report (Form 8975)?

U.S. persons that serve as the Ultimate Parent Entity (UPE) of a multinational enterprise group must file Form 8975, Country-by-Country Report, along with Schedule A (Form 8975) for each tax jurisdiction, if the group’s consolidated revenue meets or exceeds $850 million (or equivalent) in the preceding annual reporting period.

• Surrogate Parent Entity filing may apply in limited cases.
• The report includes three main tables:
  • Table 1: Aggregate financial and tax information by tax jurisdiction (revenues, profit/loss before income tax, income taxes paid or accrued, stated capital, accumulated earnings, number of employees, and tangible assets).
  • Table 2: List of all constituent entities, their tax jurisdictions, countries of organization/incorporation, and main business activities.
  • Table 3: Additional information (e.g., explanations of data sources or adjustments).

Filers generally attach the CbC report to their U.S. income tax return. The IRS exchanges the data with foreign tax authorities that have qualifying agreements in place.

Key Statistics from IRS Publication 5654 – Tax Year 2022

According to Publication 5654 and the accompanying SOI study:

• 1,966 Country-by-Country reports were filed by U.S. MNE groups for Tax Year 2022.
• Data covered 146 tax jurisdictions (economies).

These figures reflect the scale of U.S.-headquartered multinational activity worldwide. The full SOI release includes detailed Excel tables breaking down the data by:

• Major geographic regions and selected tax jurisdictions (Tables 1A, 1B, 1C, 4).
• Major industry groups (e.g., manufacturing, finance, technology) combined with regions and jurisdictions (Table 2).
• Effective tax rates (ETR) of MNE subgroups, including positive-profit and loss-making entities (Tables 3 and 4).
• Number of constituent entities by main business activity, region, and jurisdiction (Table 1D).

Separate tables distinguish between entities reporting positive profit before income tax and those with negative or zero profit, providing nuanced insights into loss positions and their geographic distribution.

Note: Individual company data remains confidential. Publication 5654 and the SOI tables present only aggregated statistics.

Why These Statistics Matter?

For tax professionals and MNEs:

• Benchmarking transfer pricing policies and effective tax rates across jurisdictions and industries.
• Assessing BEPS risks and preparing for increased scrutiny from tax authorities.
• Understanding global minimum tax (Pillar Two) implications in light of where profits and taxes are reported.

For policymakers and researchers:

• Evaluating the effectiveness of international tax reforms.
• Analyzing profit shifting patterns and the alignment (or misalignment) between economic activity and taxable income.
• Supporting data-driven discussions on tax transparency and fairness.

For the public and investors:

• Greater visibility into how large U.S. corporations operate globally, even though reports are not publicly disclosed on a company-specific basis (unlike some emerging public CbC proposals).

Data Sources, Methodology, and Limitations

The IRS Statistics of Income Division compiles the data directly from filed Forms 8975 and Schedules A. Tables undergo statistical processing to ensure confidentiality and accuracy. Detailed documentation covers sources, editing procedures, and limitations (such as differences in accounting standards, currency translation, and the fact that CbC data is not a substitute for detailed transfer pricing documentation).

Always refer to the official Tax Year 2022 Country-by-Country Report Data Sources and Limitations document on the IRS website for full context.

How to Access IRS Publication 5654 and Related Data?

1. Download Publication 5654 (PDF):
   https://www.irs.gov/pub/irs-pdf/p5654.pdf — the official one-sheet summary.
2. View detailed statistical tables:
   Visit the IRS SOI Country-by-Country Report page:
   https://www.irs.gov/statistics/soi-tax-stats-country-by-country-report
   Excel files for all 2022 tables are available there.
3. Related resources:
   • Form 8975 and Instructions
   • Country-by-Country Reporting main page
   • OECD CbC reporting guidance

Frequently Asked Questions (FAQs)

1. Is Publication 5654 the same as Form 8975 instructions?
   No. Publication 5654 is an SOI statistical summary of aggregated data. Form 8975 instructions explain how to prepare and file the report.
2. When was the 2022 data released?
   The SOI study and Publication 5654 were issued in 2025 (with the current revision dated December 2025).
3. Do all large MNEs file CbC reports?
   U.S.-parented groups meeting the $850 million threshold generally must file. Foreign-parented groups may have local filing obligations in other countries.
4. Are the reports public?
   No — individual CbC reports are confidential tax information exchanged between governments. Only aggregated statistics are published by SOI.
5. How does this relate to global minimum tax (Pillar Two)?
   CbC data helps tax authorities assess top-up tax liabilities and monitor compliance with the 15% global minimum rate.

Stay Informed on International Tax Compliance

IRS Publication 5654 and the underlying SOI data for Tax Year 2022 offer a valuable snapshot of U.S. multinational enterprise activity in a post-BEPS world. Whether you are preparing CbC filings, conducting transfer pricing analysis, or researching global tax trends, these resources provide authoritative, data-driven insights.

Download Publication 5654 today and explore the full statistical tables on the IRS website to deepen your understanding of where and how U.S. MNEs generate profits and pay taxes worldwide.

For the most current guidance, always consult official IRS publications and consult a qualified tax advisor for your specific situation. Tax rules and international agreements continue to evolve rapidly.

Sources: IRS.gov (SOI Division, International Business Tax Statistics), Publication 5654 (Rev. 12-2025), and related official documentation.