Form 8975: Country-by-Country Report
Published November 8, 2026
Form 8975 is the country-by-country report for a U.S. multinational enterprise (MNE) group. It lists the group's constituent entities and each entity's tax jurisdiction. It also reports certain information for each country. Schedules A (Form 8975) carry the detail for each tax jurisdiction. The instructions say the form reports these items annually, on a country-by-country basis.
This post is general information from the Rev. December 2020 form and its instructions. It does not say whether a group must file. That depends on the group's revenue, which is covered below.
Who must file
The instructions say a U.S. person must file Form 8975 and Schedules A (Form 8975) if it is the ultimate parent entity of a U.S. MNE group with revenues of $850 million or more in the immediately preceding reporting period. A U.S. territory ultimate parent entity may designate a U.S. business entity to file on its behalf.
The instructions say a group with annual revenue below $850 million for the preceding reporting period does not have to file.
Key terms in the instructions
- The ultimate parent entity is a U.S. business entity that owns, directly or indirectly, a sufficient interest in at least one other business entity organized or tax resident in another jurisdiction. It must be required to consolidate those accounts under U.S. GAAP, or would be if its stock were publicly traded. It is not owned by another entity that consolidates it.
- A constituent entity is any separate business entity of the group. The instructions exclude a foreign corporation or foreign partnership whose information is already required under section 6038(a). They also exclude any permanent establishment of that corporation or partnership.
- A business entity with no tax jurisdiction of residence is called "stateless."
How the schedules work
The instructions say you must attach at least one Schedule A (Form 8975). A separate Schedule A is used for each tax jurisdiction. Entities with no tax jurisdiction are reported on a stateless Schedule A. The instructions say that a filer with neither a U.S. Schedule A nor a stateless Schedule A that contains fiscally transparent U.S. business entities has not completed Form 8975 properly.
The top of each Schedule A shows the reporting period, the filer's name, and its EIN. These should match the main form. The stateless Schedule A has its own revenue and profit lines, according to the instructions.
The instructions say the country code on each schedule follows the ISO 3166-1 standard. A permanent establishment is treated as resident in the jurisdiction where it is located. A corporation organized or managed where no corporate income tax applies is treated as resident there. Another rule can change this.
When to file
Attach Form 8975 and its Schedules A to the income tax return. File by that return's due date, including extensions. The instructions list returns such as Forms 1120, 1120-C, 1120-RIC, 1065, 1120-S, 1120-L, 1120-PC, 1120-REIT, 990-T, and 1041. An extension follows the rules for the income tax return the form is attached to.
The instructions say some filers cannot file electronically. These include certain filers of Form 1120-REIT. They also include parent-entity filers of Forms 1120-C, 1120-L, 1120-PC, and 1120-RIC, and some Form 1041 filers. Those filers attach the form to the paper return.
Related topics
A foreign-owned U.S. corporation reports on Form 5472: Reporting a 25% Foreign-Owned U.S. Corporation, which is a different report. For a foreign corporation owned by U.S. persons, see Form 5471: Reporting Interests in Foreign Corporations. For the entity classification rules, see Form 8832: Choosing How Your LLC Is Taxed. For the basic corporate return, see Form 1120: The Corporate Income Tax Return and Who Must File It.
Sources: Sources: IRS, Form 8975, Country-by-Country Report (Rev. December 2020) (https://www.irs.gov/pub/irs-pdf/f8975.pdf); Instructions for Form 8975 and Schedule A (Form 8975) (Rev. December 2020) (https://www.irs.gov/pub/irs-pdf/i8975.pdf) This is general information, not advice about your specific return.
