The proposed regulations require underlying records from which the reporting corporation can prepare "material profit and loss statements" of the reporting corporation and all related attributable to "U.S.-connected products or services" - that is, products (or services) imported to, or exported from, the United States by transfers between the reporting corporation and any foreign related party.
The records to produce the material profit and loss statements should be kept under U.S.
The proposed regulations do not actually require that material profit and loss statements be created prior to a demand or summons of the IRS if they are not otherwise maintained.
As illustrated by the example below, the material profit and loss statements required may well be overlapping.
Material profit and loss statements are a major element of the recordkeeping requirement for a reporting corporation that imports products into the United State or exports products from the United States by way of transfers between it and any of its foreign related parties.
But such types of transactions do not engender the requirement to keep records from which material profit and loss statements could be produced.
The agreement can identify the material profit and loss statements of the related party group for which records are to be maintained and describe the items to be included in the profit and loss statements.
Material profit and loss statements in English are to be provided within 120 days of an IRS request.
Interest and dividends are important and both will be shown in a published profit and loss statement. Interest contributes to the profit or loss before tax.
Do's and don'ts when Reading a Profit and Loss Statement
Companies (and certain other organisations) must publish profit and loss statements. The profit and loss statements of companies must, by law, comply with one of four formats.