IRS Adds 16 Countries to Tax Data Exchange List

Administrative, Procedural, and Miscellaneous

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

(Also: 1.3406.07-00 Exceptions to Backup Withholding)

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

SECTION 1. PURPOSE

This revenue procedure supplements the listing in Revenue Procedure 2014-64, 2014-53 I.R.B. 1022, 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 of the Income Tax Regulations.

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 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. Rev. Proc. 2012-14 was updated and superseded by Rev. Proc. 2014-64. This revenue procedure supplements Rev. Proc. 2014-64 by adding 16 countries (Brazil, Czech Republic, Estonia, Gibraltar, Hungary, Iceland, India, Latvia, Liechtenstein, Lithuania, Luxembourg, New Zealand, Poland, Slovenia, South Africa, and Sweden) to the list of countries in Section 4.

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

Section 4 of Rev. Proc. 2014-64 is 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:

Rev. Proc. 2014-64 is 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) 317-5218 (not a toll-free call).