According to statements from U.S. Treasury Department Officials on 18 December 2015, regulations for Country-by-Country (CbC) reporting will be released "any day now." In addition, the IRS Large Business and International Division is already preparing for the exchange of the data in the CbC reports with other jurisdictions.
The regulations will closely follow the guidelines developed as part of Action 13 of the OECD BEPS Project and will apply for tax years beginning on or after 1 January 20…