OECD Pillar One |
Revenue |
€20 billion |
|
Form 4626, CAMT |
Pre-tax net income |
$1 billion |
59(k)(1)(B)(i), 56A |
Form 8975, Country-by-Country Report |
Revenue |
$850 million |
1.6038-4(h) |
OECD Pillar Two |
Revenue |
€750 million |
Model Rules, Article 1.1 |
Form 8991, BEAT |
Gross receipts |
$500 million |
59A(e)(1)(B) |
Covered debt instruments |
Debt instruments |
$50 million |
1.385-3(c)(4) |
Small business taxpayer |
Gross receipts |
$30 million |
448(c), Rev. Proc. 2023-34, §3.31 |
Form 1120, Schedule M-3 |
Assets |
$10 million |
Instructions to form |
Form 1120, Schedule UTP |
Assets |
$10 million |
Instructions to form |
Gain on transfer to a foreign partnership |
Built-in gain |
$1 million |
1.721(c)-2(c) |
Form 7208, Repurchase of corporate stock |
Value of repurchase |
$1 million |
4501(e)(3) |