SECTION 2. BACKGROUND

Sections 1.6049-4(b)(5) and 1.60498(a), as revised by TD 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. Section 1.6049-4(b)(5) provides that in the case of interest aggregating $10 or more paid to a nonresident alien individ­ ual (as defined in section 7701(b)(1)(B)) that is reportable under § 1.6049-8(a), the payor is required to make an information return on Form 1042-S, Foreign Person’s U.S. Source Income Subject to Withhold­ ing, for the calendar year in which the interest is paid.

Interest that is reportable under § 1.6049-8(a) is interest described in sec­ tion 871(i)(2)(A) that relates to a deposit maintained at an office within the United States. The regulations also provide that such deposit interest is reportable only if paid to a resident of a jurisdiction that is identified as a jurisdiction with which the United States has in effect an income tax or other convention or bilateral agree­ ment relating to the exchange of tax infor­ mation within the meaning of section 6103(k)(4), under which the competent authority is the Secretary of the Trea­ sury or the Secretary’s delegate and the United States agrees to provide, as well

Bulletin No. 2024–52 1433 December 23, 2024

December 23, 2024 1434 Bulletin No. 2024–52

Bulletin No. 2024–52 1435 December 23, 2024