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U.S. Publishes CbC Exchange Arrangements with Canada and Italy

20 October 2017

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Treaty Development

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United States-Canada-Italy

The U.S. IRS has published the competent authority arrangements on the exchange of Country-by-Country (CbC) reports with Canada and Italy. The arrangements were signed 7 June 2017 and 27 September 2017, respectively, and are effective from those dates. The arrangements provide that pursuant to the exchange of information provisions of the 1980 Canada-U.S. income and capital tax treaty and the 1999 Italy-U.S. income tax treaty, each competent authority intends to automatically exchange CbC reports received from each reporting entity resident for tax purposes in its jurisdiction, provided that, on the basis of the information provided in the CbC report, one...