rp-16-56.pdf

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26 CFR 1.6049.00-00: Returns Relating to Payments of Interest
(Also: 1.3406.07-00 Exceptions to Backup Withholding)

December 2016 Supplement to Rev. Proc. 2014-64, Implementation of Nonresident
Alien Deposit Interest Regulations

Rev. Proc. 2016-56

SECTION 1. PURPOSE

This revenue procedure supplements the listing in Section 3 of Revenue
Procedure 2014-64, 2014-53 I.R.B. 1022, 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, 2017.
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, and Rev. Proc. 2016-18, 2016-17 I.R.B. 635, 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(a).

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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 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superseded by Rev.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, Sections 3 and 4 of which contained updated
lists of countries. Rev. Proc. 2014-64 was supplemented by Rev. Proc. 2015-50 and
Rev. Proc. 2016-18, each of which added countries to the list in Section 4 of Rev.
Proc. 2014-64. This revenue procedure supplements Rev. Proc. 2014-64 by adding
Saint Lucia to the list of countries in Section 3 of Rev. Proc. 2014-64, and by adding
Israel, Republic of Korea, and Saint Lucia to the list of countries in Section 4 of Rev.
Proc. 2014-64.
SECTION 3. SUPPLEMENT TO SECTION 3 OF REV. PROC. 2014-64

Section 3 of Rev. Proc. 2014-64 is 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

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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
Finland
France
Germany
Gibraltar
Greece
Grenada
Guernsey
Guyana
Honduras
Hong Kong
Hungary
Iceland
India
Indonesia
Ireland
Isle of Man

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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
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

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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 and
Rev. Proc. 2016-18, 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
Brazil
Canada
Czech Republic
Denmark
Estonia
Finland
France
Germany
Gibraltar
Guernsey
Hungary
Iceland
India
Ireland
Isle of Man
Israel
Italy
Jamaica
Jersey
Korea, Republic of
Latvia
Liechtenstein
Lithuania
Luxembourg
Malta
Mauritius
Mexico
Netherlands
New Zealand
Norway
Poland
Saint Lucia

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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 and Rev. Proc.
2016-18, is further supplemented.
SECTION 6. EFFECTIVE DATE

With respect to the additional country listed in Section 3, this revenue
procedure is effective for interest paid on or after January 1, 2017.
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 procedure contact Ms. Manasterli at (202) 317-6941 (not a toll-free call).