INCOME TAX

REG–109822–15, page 535. These proposed regulations provide guidance on the information required to be reported for country-by-country (CbC) reporting. The proposed regulations generally require United States persons (other than individuals) that are the ultimate parent of a U.S. multinational enterprise (MNE) group earning annual revenues of $850,000,000 or more to report certain financial information on a tax jurisdiction-by-tax jurisdiction basis. The regulations require the U.S. ultimate parent to list the U.S. MNE group’s business entities indicating each entity’s tax jurisdiction (if any), country of organization, tax identification number (if any), and main business activity, as well as CbC financial information for each tax jurisdiction in which the U.S. MNE does business. The CbC financial information includes income, profits, income taxes, stated capital, accumulated earnings, number of employees, and tangible assets other than cash.

Rev. Rul. 2016–06, page 519. Interest rates: underpayment and overpayments. The rates for interest determined under section 6621 of the code for the calendar quarter beginning April 1, 2016, will be 4 percent for overpayments (3 percent in the case of a corporation), 4 percent for the underpayments, and 6 percent for large corporation underpayments. The rate of interest paid on the portion of a corporation overpayment exceeding $10,000 will be 1.5 percent.

Finding Lists begin on page ii.