The U.S. IRS has updated its Country-by-Country Reporting Guidance page with the addition of two model competent authority agreements for the exchange of Country-by-Country (CbC) reports. The model bilateral agreements provide for the automatic reciprocal exchange of CbC reports based on either Article 6 (Exchange of Information and Administrative Assistance)] of a tax treaty or Article (Object and Scope of this Agreement)] of a tax information exchange agreement. Since the U.S. has decided not to sign the Multilateral Competent Authority Agreement on the exchange of CbC reports, a bilateral agreement will need to be signed with each jurisdiction with which...