The U.S. IRS has published the competent authority arrangement with Japan regarding arbitration. The arrangement, signed 3 February 2021, provides for the implementation of the arbitration process provided for in paragraphs 5, 6, and 7 of Article 25 (Mutual Agreement Procedure) of the 2003 income tax treaty between the two countries as amended by the 2013 Protocol. Subject to certain exceptions, the arbitration process applies to cases that the competent authorities of Japan and the U.S. hav…