Stack says US will withdraw CbC information if made public

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2026

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Stack says US will withdraw CbC information if made public

The US will not share country-by-country report (CbCR) information with foreign authorities who choose to make the reports public, said deputy assistant secretary at the US Treasury Robert Stack.

Joelle Jefferis

Stack was speaking at the Irish Tax Institute and the Ash Center at Harvard Kennedy School’s Global Tax conference in Dublin.

Last week Stack said that he “fully expects” the US to have finalised its CbCR provisions by July this year. At the conference he reiterated his country’s commitment to implementing CbCR, but warned the US wouldn’t exchange information if a country intends to make it public.

“In the US there will be no stepping back from CbCR,” said Stack, but continued with a warning: “If a country were to make that information public, the US would have the right in our agreements to stop sending that information.”

Stack had earlier in the day spoken on another panel with Valere Moutarlier, director of the Directorate General for Taxation and Customs at the European Commission (EC). Moutarlier had mentioned that the EC are reviewing whether to publish CbC reports, with the proposal on this due to be released in April.

“We resisted heavy pressure from many quarters to rush on this proposal and we’ve taken our time to find the right balance between a high degree of public transparency and protecting the competitive interest of companies,” said Moutarlier.

Tensions surrounding taxation have been growing in recent months between the US and the EU, particularly with the EC’s state aid investigations. Stack has publically condemned the state aid investigations as unfairly targeting US multinationals, but also highlighted at the conference that tensions were created by the view that a major driver of the BEPS project is to attack US multinationals.

So long as the EC doesn’t aim to publish the information, Stack remains hopeful that CbCR will be an effective tool and of use to the US and the EU.

“Companies appreciate that CbCR is a win for the long term. There will be an uneven period while we get on the track but I do expect the whole world to get on track,” said Stack. 

more across site & shared bottom lb ros

More from across our site

The firm’s eye-catching UK launch is a major statement of intent, but it will face stern opposition in its quest to be the top global tax player
The postponement came after industry representatives flagged implementation issues with the registration regime; in other news, firms made key tax partner additions
Despite the increased yield, the time taken to resolve enquiries was at a six-year high, new HMRC statistics have revealed
The High Court’s dismissal of barrister Setu Kamal’s legal challenge represents the first successful strike-out under a new law on SLAPPs
IP lawyers, who say they are encouraging clients to build up ‘tariff resilience’, should treat the risks posed by recent orders as a core consideration in cross-border licensing
As Coca-Cola awaits a crucial 11th Circuit Court of Appeals decision this year, its multibillion-dollar tax dispute could have profound implications for investors, cash flow, and corporate transparency
However, women in tax face greater career obstacles than their male counterparts, an exclusive ITR survey of more than 100 women tax leaders revealed
Under Jeff Soar’s leadership, WTS UK aims to scale to 100 partners within five years and challenge the big four
As the firm embarks on a major shakeup of its EMEA partnerships, some staff will be watching nervously
The buyout of Hucke and Associates continues Ryan’s streak of firm acquisitions; in other news, a UK appeal against VAT on private school fees was dismissed
Gift this article