This bill expressly prohibits the Department of the Treasury from collecting from a U.S. person or transmitting to any foreign jurisdiction any country-by-country report (CbCR) information of any U.S. person for taxable years beginning before January 1, 2017. CbCR information is used by the Organization for Economic Cooperation and Development to develop its Base Erosion and Profit Shifting (BEPS) Action Plan to increase the transparency of transfer pricing practices and other tax transactions of multinational business enterprises.
Treasury must: (1) suspend the transmittal of CbCR information of any U.S. person to a foreign jurisdiction if it determines that such jurisdiction is abusing BEPS master file documentation requirements or failing to safeguard the confidentiality of information required in the master file, and (2) report to the congressional tax committees on allegations or reports received concerning the abuse of master file documentation requirements and any actions taken with respect to such allegations.