SECTION 2. BACKGROUND
Internal Revenue Bulletin 2017-43 · 2026-10-03 edition · updated 2026-10-04 · United States
Sections 1.6049–4(b)(5) and 1.6049– 8(a), as revised by T.D. 9584, 2012–20 I.R.B. 900, 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 T.D. 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 Proc. 2012–24 was updated and superseded by Rev.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 Rev.
Proc. 2014–64 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, Rev. Proc. 2016–56, and Rev. Proc. 2017–31. This revenue procedure further supplements Rev. Proc. 2014–64 by adding the Faroe Islands and Greenland to the list of countries in Section 3 of Rev. Proc. 2014–64 and by adding Croatia and Panama to the list of countries in Section 4 of Rev. Proc. 2014– 64.
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