IRS Adds 3 Countries to Tax Data Exchange List

Superseded by Rev. Proc. 2018-36

March 2017 Supplement to Rev. Proc. 2014-64,
Implementation of Nonresident Alien Deposit Interest Regulations

26 CFR 1.6049.00-00: Returns Relating to Payments of Interest

(Also: 1.3406.07-00 Exceptions to Backup Withholding)

SECTION 1. PURPOSE

This revenue procedure supplements the listing in Section 4 of Revenue Procedure 2014-64, 2014-53 I.R.B. 1022, as previously supplemented by Rev. Proc. 2015-50, 2015-42 I.R.B. 583, Rev. Proc. 2016-18, 2016-17 I.R.B. 635, and Rev. Proc. 2016-56, 2016-52 I.R.B. 920, of the countries with which the Department of the Treasury (Treasury Department) and the Internal Revenue Service (IRS) have determined that it is appropriate to have an automatic exchange relationship with respect to the information collected under §§ 1.6049-4(b)(5) and 1.6049-8(a).

SECTION 2. BACKGROUND

Sections 1.6049-4(b)(5) and 1.6049-8(a), as revised by TD 9584, require the reporting of certain deposit interest paid to nonresident alien individuals on or after January 1, 2013. Rev. Proc. 2012-24, 2012-20 I.R.B. 913, was published contemporaneously with the publication of TD 9584. Section 3 of that revenue procedure identified those countries with which the United States has in force an information exchange agreement, such that interest paid to residents of such countries must be reported by payors to the extent required under §§ 1.6049-4(b)(5) and 1.6049-8(a). Section 4 of that revenue procedure identified the countries with which the Treasury Department and the IRS had determined that it was appropriate to have an automatic exchange relationship with respect to the information collected under §§ 1.6049-4(b)(5) and 1.6049-8(a). Rev. Proc. 2012-24 was updated and superseded by Rev. Proc. 2014-64, Section 4 of which contained an updated list of countries with which an automatic exchange relationship had been determined appropriate. Rev. Proc. 2014-64 was supplemented by Rev. Proc. 2015-50, Rev. Proc. 2016-18, and Rev. Proc. 2016-56, each of which added countries to the list in Section 4 of Rev. Proc. 2014-64. This revenue procedure further supplements Rev. Proc. 2014-64 by adding Belgium, Colombia, and Portugal to the list of countries in Section 4 of Rev. Proc. 2014-64.

SECTION 3. SUPPLEMENT TO SECTION 4 OF REV. PROC. 2014-64

Section 4 of Rev. Proc. 2014-64, as supplemented by Rev. Proc. 2015-50, Rev. Proc. 2016-18, and Rev. Proc. 2016-56, is further supplemented to read as follows:

The following list identifies the countries with which the automatic exchange of the information collected under §§ 1.6049-4(b)(5) and 1.6049-8 has been determined by the Treasury Department and the IRS to be appropriate:

• Australia

• Azerbaijan

• Belgium

• Brazil

• Canada

• Colombia

• Czech Republic

• Denmark

• Estonia

• Finland

• France

• Germany

• Gibraltar

• Guernsey

• Hungary

• Iceland

• India

• Ireland

• Isle of Man

• Israel

• Italy

• Jamaica

• Jersey

• Korea, Republic of

• Latvia

• Liechtenstein

• Lithuania

• Luxembourg

• Malta

• Mauritius

• Mexico

• Netherlands

• New Zealand

• Norway

• Poland

• Portugal

• Saint Lucia

• Slovak Republic

• Slovenia

• South Africa

• Spain

• Sweden

• United Kingdom

SECTION 4. EFFECT ON OTHER DOCUMENTS

Rev. Proc. 2014-64, as supplemented by Rev. Proc. 2015-50, Rev. Proc. 2016-18, and Rev. Proc. 2016-56, is further supplemented.

SECTION 5. DRAFTING INFORMATION

The principal author of this revenue procedure is Jackie Bennett Manasterli of the Office of Associate Chief Counsel (International). For further information regarding this revenue procedure contact Ms. Manasterli at (202) 317-6941 (not a toll-free call).