US IRS released an updated withholding foreign partnership agreement (WP agreement) and a withholding foreign trust agreement (WT agreement). The IRS also published an advance version of the Revenue Procedure 2017-23 addressing the process for filing the Country-by-Country (CbC) Report and other related documentation by ultimate parent entities of U.S. MNE groups.
Qualified Intermediary Withholding Agreement
The objective of the foreign partnership (WP) and withholding foreign trust (WT) is to allow a foreign partnership or foreign trust to become a WP or WT and to assume the withholding and reporting obligations under Chapters 3 and 4 of the Code for payments of U.S. source income (such as interest, dividends, and royalties) made to its partners, beneficiaries, or owners, and in some cases, persons holding interests in the WP or WT through one or more foreign intermediaries or flow-through entities. The agreements replace earlier versions provided in Revenue Procedure 2014-47.
Early CbC Filing Form
The IRS also released Revenue Procedure 2017-23, which describes the process for filing the Country-by-Country Report and Schedule A, Tax Jurisdiction and Constituent Entity Information by ultimate parent entities of U.S. MNE groups for reporting periods beginning on or after January 1, 2016. The filing procedure provided by the Revenue Procedure 2017-23 explains that starting September 1, 2017, Form 8975 may be filed for an early reporting period.
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