Through correspondence with the U.S. IRS, further clarification has been provided in relation to recently reported comments that the IRS may not be able to finalize all required CbC exchange arrangements (CAA) by the end of 2017. Additional points of clarification as provided by the IRS include: The IRS’s International Division continues to make negotiating and concluding CbC CAAs their top priority. The International Division is prioritizing concluding CAAs with jurisdictions that have a local filing requirement for tax year 2016. For these CAAs, although they cannot say with certainty where things will stand at the end of the calendar...