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U.S. IRS Expects CbC Report Exchange Agreements to be Completed in Timely Manner but May Not Cover all Countries

13 March 2017

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Treaty Development

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United States

While speaking at the Pacific Rim Tax Conference held 9 March 2017 in Redwood City, California, Commissioner Douglas O'Donnell of the IRS Large Business and International Division noted the status of negotiations for competent authority agreements for the purpose of exchanging CbC reports. According to O'Donnell, negotiations are ongoing with jurisdictions that currently have both information exchange instruments with the U.S. and adequate data safeguards. The IRS expects that the competent authority agreements will be completed in a timely manner, but O'Connell also acknowledged the concerns of stakeholders given the absence of any signed agreements to date and noted that...