The grandfathered CAP privately held and/or grandfathered foreign owned taxpayer must submit unaudited quarterly financial statements under U.S. GAAP 45 days after the end of the quarter. For the 2020 Compliance Assurance Process only, the grandfathered CAP taxpayer may combine the first quarter and second quarter unaudited U.S. GAAP financial statement results and submit these statements 45 days after the end of the second quarter.
The legal reasoning behind this requirement is to ensure timely and accurate financial reporting within the CAP Program, which helps maintain transparency and compliance with U.S. GAAP standards. This submission timeline allows the IRS to review the financial health and compliance status of the taxpayer on a quarterly basis, ensuring that any issues can be identified and addressed promptly.
Sources:
IRS FAQ
