The U.S. IRS has published the competent authority arrangements on the exchange of Country-by-Country (CbC) reports with Canada and Italy. The arrangements were signed 7 June 2017 and 27 September 2017, respectively, and are effective from those dates.
The arrangements provide that pursuant to the exchange of information provisions of the 1980 Canada-U.S. income and capital tax treaty and the 1999 Italy-U.S. income tax treaty, each competent authority intends to automatically exchange CbC …