The U.S. IRS has published the bilateral competent authority arrangement on the exchange of Country-by-Country (CbC) reports with Bermuda. The arrangement was signed 7 December 2017 and is operative (effective) from that date. The arrangement is non-reciprocal and provides that pursuant to Article 3 (Exchange of Information) of the 1988 Bermuda-United States tax information exchange agreement, the Bermuda competent authority intends to automatically exchange with the United States competent authority the CbC Report received from each reporting entity that is resident for tax purposes in Bermuda, provided that, on the basis of the information provided in the CbC Report, one...