The ITPF News Blog is managed by the students at the University of Florida Levin College of Law International Tax LLM Program.
Differences between the effective dates in the proposed country-by-country (CbC) reporting regulations (REG-109822-15) issued by Treasury and the IRS and those in the report on action 13 (transfer pricing documentation) of the OECD's base erosion and profit-shifting program may create timing mismatch problems, according to KPMG's Manal Corwin and Kimberly Tan Majure.
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