- Who has to file
- The detail people miss: it's last year's revenue that counts
- What goes on Form 8975 and Schedule A
- Definitions that decide where an entity goes
- The stateless schedule
- How and when to file
- Why the IRS cares about electronic filing
- Records and reconciliation
- The verdict
- Frequently asked questions
Form 8975 is the country-by-country report a U.S. company files when it's the ultimate parent of a multinational group with revenue of $850 million or more in the preceding reporting period. It lists every entity in the group and, for each tax jurisdiction, the group's revenue, profit, tax, capital, earnings, tangible assets and employees.
Everything here comes from the IRS Instructions for Form 8975 and Schedule A (Rev. December 2020), the current revision as of October 2026.
Who has to file
A U.S. person must file if it's the ultimate parent entity of a U.S. multinational enterprise (MNE) group with revenue of $850 million or more in the immediately preceding reporting period. A group below that figure doesn't file. A U.S. territory ultimate parent can designate a U.S. business entity to file for it.
The ultimate parent is a U.S. business entity that has to consolidate the accounts of at least one foreign entity under U.S. GAAP, or would if it were publicly traded, and isn't itself consolidated by another entity above it.
The detail people miss: it's last year's revenue that counts
The $850 million test looks back. A group that crosses the line this year doesn't file for this year; it files for the next reporting period, because the trigger is revenue in the immediately preceding period. Entities included only through equity-method or fair-value accounting aren't part of the group, but entities left out of consolidation purely on size or materiality grounds still are.
What goes on Form 8975 and Schedule A
| Section | What it holds |
|---|---|
| Part I | The filer's name, EIN, address and reporting role: ULT for an ultimate parent, SUR for a designated filer |
| Part II | Additional information about the group, as much as you need |
| Schedule A, one per tax jurisdiction | Each constituent entity, its jurisdiction, country of organization and main business activities |
| Schedule A financial data | Revenues, profit or loss, income tax paid and accrued, stated capital, accumulated earnings, tangible assets other than cash, number of employees |
Employees are reported as an aggregate number for each jurisdiction, and the instructions allow rounding or approximation as long as it doesn't materially distort how employees are spread across jurisdictions.
Definitions that decide where an entity goes
| Term | What the instructions say |
|---|---|
| Tax jurisdiction | A country, or a place that isn't a country but has fiscal autonomy; U.S. territories count |
| Tax jurisdiction of residence | Where an entity is liable to tax because of its place of management, organization or a similar basis |
| No-income-tax country | A corporation organized or managed there is treated as resident there, unless it's resident somewhere else under the normal rules |
| Permanent establishment | A branch treated as a PE under a treaty, taxed locally under domestic law, or taxed as a separate entity by its owner's country; it's reported where it's located |
| Business entity | Includes single-owner disregarded entities and PEs that prepare separate financial statements, but not a decedent's estate or a bankruptcy estate |
A tax charged only on gross amounts of local-source income or local capital, with no deduction for expenses, doesn't make an entity resident in that jurisdiction. So being taxed on a few payments from a country isn't enough to put an entity on that country's Schedule A.
The stateless schedule
An entity with no tax jurisdiction of residence is treated as "stateless" and goes on its own Schedule A. The instructions add a check: if a filer has neither a U.S. Schedule A nor a stateless Schedule A that contains its fiscally transparent U.S. business entities, the Form 8975 hasn't been completed correctly.
How and when to file
- Attach Form 8975 and every Schedule A to the income tax return of the ultimate parent. Don't file them separately.
- File by the due date of that return, including extensions; an extension of the return extends the report.
- If you e-file Form 1120, 1065, 1120-S, 990-T or 1041, attach the report electronically in the correct format, not as a binary attachment.
- If you file on paper, also mail a copy of page 1 of Form 8975 to the IRS at Mailstop 4950, 1973 N. Rulon White Blvd., Ogden, UT 84201.
The return could be a Form 1120, 1120-C, 1120-RIC, 1065, 1120-S, 1120-L, 1120-PC, 1120-REIT, 990-T or 1041. To amend, you file an amended Form 8975 with every Schedule A, including the ones that haven't changed, with an amended return.
Why the IRS cares about electronic filing
The instructions encourage electronic filing "to ensure the timely automatic exchange" of the report. Form 8975 isn't only for the IRS: the information is exchanged with other tax jurisdictions. That's a good reason to treat the jurisdiction figures as something a foreign tax authority may read, and to keep them consistent with what your foreign subsidiaries report locally.
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Records and reconciliation
You must keep records that support the figures. You aren't required to create records reconciling the report to tax returns or financial statements, and the reporting period is generally the 12-month period of your applicable financial statement that ends with or within your tax year. Groups that also file Form 5471 for their foreign subsidiaries will recognise many of the same entity details.
The verdict
Form 8975 is a compliance job for large groups, not a tax calculation. The risks are filing it a year late because nobody tracked the $850 million look-back, missing the stateless schedule, and sending numbers that don't line up with what subsidiaries tell their own tax offices. Build the jurisdiction data once a year from your consolidation package and the form almost fills itself.
Frequently asked questions
Who must file Form 8975?
A U.S. person that's the ultimate parent entity of a U.S. multinational group with revenue of $850 million or more in the immediately preceding reporting period.
Is Form 8975 filed separately?
No. Form 8975 and its Schedules A are attached to the ultimate parent's income tax return and filed by its due date, including extensions.
What is Schedule A of Form 8975?
It's the per-jurisdiction schedule listing each constituent entity and the group's revenues, profit, income tax paid and accrued, stated capital, accumulated earnings, tangible assets and employees there.
What does a stateless entity mean on Form 8975?
It's a business entity with no tax jurisdiction of residence. It's reported on a separate Schedule A for the jurisdiction "stateless".
Do paper filers of Form 8975 do anything extra?
Yes. They mail a copy of page 1 of Form 8975 to the IRS at Mailstop 4950 in Ogden, UT 84201, so the IRS can identify the paper report.
