The US Internal Revenue Service (IRS) has released IRS Announcement 2012-31 with the official text of the recent competent authority agreement between the United States and Canada. The announcement is dated 20 August 2012. The competent authority agreement was entered into under article XXVI(3) (Mutual Agreement Procedure) of the 1980 US-Canada Income Tax Treaty. The agreement addresses the application of the principles set forth in the Organization for Economic Cooperation and Development (OECD) Report on the Attribution of Profits to Permanent Establishments (the "authorized OECD approach" or "full AOA") in the interpretation of article VII (Business Profits) of the Treaty (the OECD Report)....