ITS Washington Dispatch, November 2017

US House and Senate pass competing tax reform bills – IRS concludes GRA becomes fixed on date of initial transfer – IRS may not complete planned competent authority agreements for CbCR by year end – US-Argentina tax information exchange agreement in force – IRS outlines additional international tax compliance initiatives – US to appeal ruling IRS violated APA regarding anti-inversion regulations – OECD releases additional CbCR guidance – OECD issues 2016 MAP statistics – OECD Council approves 2017 update to Model Tax Convention – OECD holds second consultation on attribution of profits to PEs, and profit splits – OECD publishes updated TP country profiles