According to recent reports, U.S. Treasury Attorney Advisor Brian Jenn has stated that the Treasury may implement an earlier filing deadline for country-by-country (CbC) reports than the deadline provided for in the OECD BEPS Action 13 Guidelines. Under the guidelines, the parent entity of a multinational group would be required to file the initial CbC report by 31 December 2017, in respect of the tax year ending December 31 2016. However, the Treasury is considering an initial filing deadline of 31 September 2017. The Treasury and the IRS are also considering whether the CbC report will be part of the...