Overview
IRS Issues Additional Country-by-Country Reporting Guidance: Notice 2018-31 provides additional guidance concerning country-by-country (CbC) reporting requirements under section 6038. The notice describes intended amendments to the CbC reporting requirements under Treas. Reg. § 1.6038-4 with respect to certain US multinational enterprise groups with revenue attributable to contracts with the Department of Defense or other US government intelligence or security agencies. Prior to the issuance of these amendments, US groups may rely on the provisions described in the notice.
IRS Publishes Advance Pricing Agreement Report: Announcement 2018-08 sets out Treasury’s annual report to the public concerning advance pricing agreements and the experience, structure, and activities of the Advance Pricing Mutual Agreement Program during calendar year 2017.