President Trump releases tax reform plan; calls for territorial system and repatriation of foreign earnings -- President Trump signs executive order requiring review of tax regulations – Modification of variable prepaid forward contracts does not trigger gain realization, Tax Court holds – IRS issues annual APA report for 2016; uptick in Indian APA cases – IRS extends deadline for submitting QI, WP, and WT agreement renewal requests to 31 May – OECD updates guidance on Country-by-Country Reporting.