At a glance
#Dates are for an example year end of Dec 31, 2025. Where local law moves a deadline on a weekend or national public holiday to the next working day, the date shown is already moved. Use the Deadlines tool for your own year end and thresholds.
Verified 2026-10-26. Tax authority: Internal Revenue Service (IRS). Summaries are simplified; check the linked official source before relying on them.
The law
#IRC s. 482 and Treas. Reg. ss. 1.482-1 to 1.482-9; penalties in IRC s. 6662(e) and (h) with Treas. Reg. s. 1.6662-6; information reporting in IRC ss. 6038A/6038C (Form 5472) and Treas. Reg. s. 1.6038-4 (Form 8975 CbC). The US applies its own regulations, not the OECD Guidelines, though the approach is broadly consistent.
Documentation
#No mandatory Master File or Local File. To avoid the s. 6662(e) penalty a taxpayer needs 'principal documents' showing it reasonably used a method under the best method rule; they must exist when the return is filed and be given to the IRS within 30 days of a request (Treas. Reg. s. 1.6662-6(d)). Form 5472 for 25% foreign-owned US corporations and foreign corporations with a US business that have reportable related-party transactions. Form 8975 for US parents with group revenue of $850 million or more.
Methods
#Best method rule (Treas. Reg. s. 1.482-1(c)). Tangible goods: CUP, resale price, cost plus, CPM, profit split; intangibles: CUT, CPM, profit split; services: services cost method, comparable services price, gross services margin, cost of services plus, CPM, profit split. Arm's length range is ordinarily the interquartile range (25th to 75th percentile); if the result is outside, the IRS adjusts to the median (s. 1.482-1(e)(2)(iii)(C) and (e)(3)).
Penalties
#s. 6662(e): 20% penalty if the net s. 482 adjustment exceeds the lesser of $5 million or 10% of gross receipts; s. 6662(h): 40% if it exceeds the lesser of $20 million or 20% of gross receipts. Documentation that exists at filing and is given within 30 days protects against these. Form 5472: $25,000 per form per year, plus $25,000 for each 30 days a failure continues more than 90 days after IRS notice (s. 6038A(d)).
Pillar Two
#The United States has not adopted Pillar Two: there is no US IIR, UTPR or QDMTT and no US GloBE filing. Under the OECD side-by-side package (January 2026), the US is the only Qualified Side-by-Side Regime, so for fiscal years starting on or after 1 January 2026 US-parented groups get a safe harbour that sets IIR and UTPR top-up tax to nil. Foreign QDMTTs still apply, and US groups still need a GloBE Information Return filed through a designated filing entity abroad (a simplified one from 2026).
Other rules
#APA program (Rev. Proc. 2015-41) and MAP. Secondary adjustments: conforming cash or account adjustments under Rev. Proc. 99-32. Interest limitation under s. 163(j) (30% of adjusted taxable income). No CbC notification requirement. Calendar-year C corporations: Form 1120 due 15 April; fiscal years: 15th day of the 4th month. Transitional rule: a C corporation with a 30 June year end that began before 1 January 2026 (so FYE 30 June 2026) still files by the 15th day of the 3rd month (15 September 2026) with a 7-month extension.
Filings and deadlines
#| # | Filing | When | Who | Source |
|---|---|---|---|---|
| 1 | Form 1120 corporate income tax return 15th day of the 4th month after year end (IRC s. 6072(a)). Automatic 6-month extension with Form 7004 (s. 6081(b)); tax is still due on the original date. Exception for FYEs in 2026: a 30 June 2026 year end (year began before 2026) is due the 15th day of the 3rd month with a 7-month extension. Weekend or holiday dates roll to the next business day. | Extended: Form 7004, automatic 6-month extension (e.g. Oct 15, 2026); original due date Apr 15, 2026 | All C corporations (Form 1120-F for foreign corporations). | 26 U.S.C. 6072 |
| 2 | Form 5472 information return (25% foreign-owned US corporation or foreign corporation with US business) Filed with the income tax return by its due date including extensions (Treas. Reg. s. 1.6038A-2(d)). Penalty $25,000 per failure. | With Form 1120 corporate income tax return (extended) (e.g. Oct 15, 2026); original due date Apr 15, 2026 | A reporting corporation (at least 25% foreign-owned, or foreign corporation engaged in a US trade or business) with any reportable transaction with a foreign or domestic related party. One form per related party. | 26 CFR 1.6038A-2 |
| 3 | Form 5471 information return (US persons with certain foreign corporations) Filed with the income tax return by its due date including extensions. Penalty USD 10,000 for each foreign corporation for each annual accounting period (IRC s. 6038(b)), plus USD 10,000 for each 30 days the failure continues more than 90 days after an IRS notice, up to USD 50,000 more. | With Form 1120 corporate income tax return (extended) (e.g. Oct 15, 2026); original due date Apr 15, 2026 | US persons who are officers, directors or shareholders of certain foreign corporations, including US shareholders of controlled foreign corporations (CFCs). | IRS: Instructions for Form 5471 |
| 4 | s. 6662(e) TP documentation (penalty protection) Principal documents must be in existence when the return is filed (extended due date if extended). | With Form 1120 corporate income tax return (extended) (e.g. Oct 15, 2026); original due date Apr 15, 2026 | Optional, but needed by any taxpayer with related-party transactions that wants protection from the 20% and 40% valuation penalties. | 26 CFR 1.6662-6(d)(2)(iii) |
| 5 | Form 8975 Country-by-Country Report (with Schedule A) Filed with the parent's income tax return for the year in or with which the reporting period ends, by the due date including extensions (Treas. Reg. s. 1.6038-4). No separate notification. | With Form 1120 corporate income tax return (extended) (e.g. Oct 15, 2026); original due date Apr 15, 2026 | US ultimate parent entity of a US MNE group with annual revenue of $850 million or more in the preceding reporting period (group revenue, not entity revenue). | 26 CFR 1.6038-4 |
| 6 | Provide s. 6662(e) documentation on IRS request Within 30 days of an IRS request in an examination. | Within 30 days of a tax authority request | Taxpayers relying on documentation for penalty protection. | 26 CFR 1.6662-6(d)(2)(iii)(A) |