SECTION 2. BACKGROUND
Internal Revenue Bulletin 2017-16 · 2026-10-03 edition · updated 2026-10-04 · United States
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 agree
ment, 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 Proc. 2012–24 was updated and superseded by Rev.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.
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