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With the finalization of the IRS’ country-by-country (“CbC”) reporting regulations, U.S. taxpayers are now confronted with the first set of actionable rules arising from the OECD’s Base Erosion and Profiting Shifting initiative. To compound the complexity, CbC reporting rules have now been adopted or introduced in over 20 other countries (and counting) — which means the pressure on CbC disclosures is mounting.
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