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I.R.S. Pushes to Ease Implementation of Country-by-Country Reporting for U.S. M.N.E.’s

Volume 4 No 6    /    Read Article

By Galia Antebi and Kenneth Lobo

It is widely known that the U.S. is following its own path towards international tax compliance. It has not signed onto the O.E.C.D.'s Multilateral Competent Authority Agreement on the Exchange of Country-by-Country Reports; it does not participate in the Common Reporting Standard; and it did not sign the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent B.E.P.S. Nonetheless, at the request of U.S. multinationals, the I.R.S. has adopted domestic income tax regulations on country-by-country (“CbC”) reporting. In May, the I.R.S. confirmed the first bilateral competent authority agreement regarding CbC reporting was signed with the Netherlands. That agreement has now been followed by agreements with Canada, Denmark, Guernsey, Iceland, Ireland, Korea, Latvia, New Zealand, Norway, Slovakia, and South Africa. Galia Antebi and Kenneth Lobo delve into the U.S. rules and forms for CbC reports.   See more →