According to recent reports, Assistant Deputy Commissioner (International) of the U.S. IRS Large Business and International Division, Theodore Setzer, has stated that it is unlikely that the U.S. will be able to finalize all required Country-by-Country (CbC) Report exchange arrangements by the end of the year. The comment was made while speaking at the 5th Annual International Tax Enforcement and Controversy Conference in Washington, DC on 27 October 2017. To date, the U.S. has signed competent authority arrangements on the exchange of CbC reports with 29 jurisdictions and negotiations are ongoing with at least 13 others. For U.S. MNEs that...