The IRS has released Revenue Procedure 2015-50 (RP 2015-50). It updates a previous revenue procedure, 2014-64 (published in December 2014) with a list of additional countries with which the United States has determined it is appropriate to have an automatic exchange of information relationship.
RP 2015-50 adds 16 countries with which the United States has, in effect an income tax or convention or bilateral agreement relating to the exchange of information with other countries. The list of 16 countries includes New Zealand.
This relates only to bank deposit interest information collected on certain non-resident aliens under IRC Reg. 1.6049-8(a) and 1.6049-4(b)(5).
Under Regs. 1.6049-8(a) and 1.6049-4(b)(5) payments of interest to residents of these countries must be reported to the IRS on Form 1042-S Foreign Person’s U.S. Source Income Subject to Withholding.
Whilst many countries may have a tax information exchange agreement (TIEA) with the United States in force, only a subset of those countries have been determined by the IRS to be countries with which the automatic exchange of deposit information is appropriate.
The determination is based upon a FATCA-related safeguards assessment.
RP 2015-50 lists those countries and now confirms 34 countries to which the information reported on Form 1042-S may be passed by the Treasury and the IRS.