On March 15, 2019, the IRS released a new practice unit entitled “Introduction to Traditional Automatic Exchange of Information.” The practice unit provides a summary of the procedures for the IRS Automatic Exchange of Information or AEOI Program, which administers the regular and automatic exchange of taxpayer information required by tax treaties and Tax Information Exchange Agreements or TIEAs between the United States and foreign governments. Such “traditional” exchanges can be contrasted with the exchange of information under newer programs like FATCA or the OECD’s BEPS project.
As explained on the IRS website, practice units provide a general discussion regarding concepts, processes, or transactions and serve as a means to collaborate and share information and knowledge for employees of the IRS. Practice units are not official guidance, are not official pronouncements of law or directives, and cannot be cited or relied upon as legal authority. They merely provide useful context and practical information for taxpayers, and taxpayers should independently confirm information provided in practice units with applicable legal authorities before relying on information found in the practice units.