rp-17-46.pdf

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26 CFR 601.201: Rulings and determination letters
(Also Part 1, §§ 6049; 1.6049-4, 1.6049-8)

September 2017 Supplement to Rev. Proc. 2014-64, Implementation of Nonresident
Alie n Deposit Interest Regulations

Rev. Proc. 2017-46

SECTION 1. PURPOSE

This revenue procedure supplements the listing in Section 3 of Revenue Procedure
2014-64, 2014-53 I.R.B. 1022, as previously supplemented by Rev. Proc. 2016-56,
2016-52 I.R.B. 920, of the countries with respect to which the reporting requirement of
§§ 1.6049-4(b)(5) and 1.6049-8(a) of the Income Tax Regulations applies, effective for
interest paid on or after January 1, 2018.
This revenue procedure also supplements the listing in Section 4 of Revenue
Procedure 2014-64, as previously supplemented by Rev. Proc. 2015-50, 2015-42
I.R.B. 583, Rev. Proc. 2016-18, 2016-17 I.R.B. 635, Rev. Proc. 2016-56, and Rev.
Proc. 2017-31, 2017-16 I.R.B. 1104, of the countries with which the Department of the
Treasury (Treasury Department) and the Internal Revenue Service (IRS) have

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determined that it is appropriate to have an automatic exchange relationship with
resp ect to the information colle cted under §§ 1.6049-4(b)(5) and 1.6049-8(a).

SECTION 2. BACKGROUND

Secti ons 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 alie n 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 co untries with which the
Treasury Department and the IRS had determined that it was appropriate to have an
automatic exchange relationship with resp ect to the information colle cted 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 Proc. 2012-24 was updated and superseded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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SECTION 3. SUPPLEMENT TO SECTION 3 OF REV. PROC. 2014-64
Section 3 of Rev. Proc. 2014-64, as previously supplemented by Rev. Proc. 2016-
56, is further supplemented to read as follows:
The following are the countries with which the United States has in effect an
income tax or other convention or bilateral agreement relating to the exchange of tax
information within the meaning of section 6103(k)(4) pursuant to which the United
States agrees to provide, as well as receive, information and under which the
competent authority is the Secretary of the Treasury or his delegate:
Antigua & Barbuda
Aruba
Australia
Austria
Azerbaijan
Bangladesh
Barbados
Belgium
Bermuda
Brazil
British Virgin Islands
Bulgaria
Canada
Cayman Islands
China
Colombia
Costa Rica
Croatia
Curacao
Cyprus
Czech Republic
Denmark
Dominica
Dominican Republic
Egypt
Estonia
Faroe Islands

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Finland
France
Germany
Gibraltar
Greece
Greenland
Grenada
Guernsey
Guyana
Honduras
Hong Kong
Hungary
Iceland
India
Indonesia
Ireland
Isle of Man
Israel
Italy
Jamaica
Japan
Jersey
Kazakhstan
Korea, Republic of
Latvia
Liechtenstein
Lithuania
Luxembourg
Malta
Marshall Islands
Mauritius
Mexico
Monaco
Morocco
Netherlands
Netherlands island territories: Bonaire, Saba, and St. Eustatius
New Zealand
Norway
Pakistan
Panama
Peru
Philippines
Poland

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Portugal
Romania
Russian Federation
Saint Lucia
Slovak Republic
Slovenia
South Africa
Spain
Sri Lanka
St. Maarten (Dutch part)
Sweden
Switzerland
Thailand
Trinidad and Tobago
Tunisia
Turkey
Ukraine
United Kingdom
Venezuela

SECTION 4. 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, Rev. Proc. 2016-56, and Rev. Proc. 2017-31, 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
Croatia
Czech Republic
Denmark

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Estonia
Finland
France
Germany
Gibraltar
Guernsey
Hungary
Iceland
India
Ireland
Isle of Man
Israel
Italy
Jamaica
Je rse y
Korea, Republic of
Latvia
Liechtenstein
Lithuania
Luxembourg
Malta
Mauritius
Mexico
Netherlands
New Zealand
Norway
Panama
Poland
Portugal
Saint Lucia
Slovak Republic
Slovenia
South Africa
Spain
Sweden
United Kingdom

SECTION 5. EFFECT ON OTHER DOCUMENTS
Rev. Proc. 2014-64, as supplemented by Rev. Proc. 2015-50, Rev. Proc. 2016-18,
Rev. Proc. 2016-56, and Rev. Proc. 2017-31, is further supplemented.

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SECTION 6. EFFECTIVE DATE
With respect to the additional countries listed in Section 3, this revenue procedure is
effective for interest paid on or after January 1, 2018.
SECTION 7. 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 proce dure, co ntact Ms. Manasterli at (202) 317-6941 (not a toll- free ca ll) .