The U.S. IRS has published the bilateral competent authority arrangement on the exchange of Country-by-Country (CbC) reports with Bermuda. The arrangement was signed 7 December 2017 and is operative (effective) from that date.
The arrangement is non-reciprocal and provides that pursuant to Article 3 (Exchange of Information) of the 1988 Bermuda-United States tax information exchange agreement, the Bermuda competent authority intends to automatically exchange with the United States competent…