
Form 8975 Country-by-Country Reporting in 2026: The $850M Threshold, Schedule A Mechanics, and the Pillar Two Safe Harbor
U.S. multinationals with $850M+ in consolidated revenue file Form 8975 with Schedule A per jurisdiction. In 2026 the report also gates the OECD Pillar Two transitional safe harbor at a 17% simplified ETR — making CbC data accuracy a strategic, not clerical, priority.










