On January 12, 2017, TEI Executive Director Eli Dicker and Tax Counsel Benjamin Shreck participated in a roundtable discussion of the IRS’s administration of country-by-country (CbC) reporting. The discussion focused on the CbC forms, instructions and guidance, external communication and outreach, compliance and enforcement issues, as well as international exchange and use of CbC information.
During the roundtable, TEI emphasized the need for the IRS to provide clear guidance on what constitutes the misuse of CbC information and to provide a clear and responsive avenue for taxpayers to inform the Service when foreign tax authorities use CbC information in an inappropriate manner. TEI also requested that the IRS provide real time notice and updates of the countries with which it is sharing taxpayer CbC reports, and in particular countries that it is no longer sharing CbC reports to ensure taxpayer can meet their compliance obligations in other jurisdictions.
The discussion was led by IRS Assistant Deputy Commissioner International Ted Setzer and attended by other high-level IRS officials, including Commissioner John Koskinen, Deputy Commissioner for Services and Enforcement John Dalrymple, and Commissioner of LB&I Doug O’Donnell.