US Treasury announced on 31 July 2015 that the US government intends to develop regulations implementing the OECD/G20 base erosion and profit shifting (BEPS) action plan guidance on country-by-country (CbC) reporting by multinational enterprises.
The US Treasury plan, which describes 277 tax guidance projects that the government intends to work on from July 2015 through June 2016, includes a new project to draft “regulations under §§6011 and 6038 relating to the country-by-country reporting of income, earnings, taxes paid, and certain economic activity for transfer pricing risk assessment.”