In exclusive tax law commentary for SPA Members, Thomas A. Humphreys of Morrison & Foerster analyzes the July 19, 2007 Wall Street Journal article reporting that the Internal Revenue Service is seeking information from a couple of Wall Street banks about cross-border derivative transactions. What’s this all about and how does it affect structured products? According to the Journal, information document requests ("IDRs") have been issued to Citigroup and Lehman Brothers "relating to the use of derivatives by offshore investors". IDRs are IRS requests for documents with respect to a taxpayer under audit (there’s even a form: IRS Form 4564). The article goes on to say that the IRS is looking at crossborder dividend withholding. 

Click here for the analysis:  http://www.structuredproducts.org/img/catfiles/36/i0/57_SPA%20Regulatory%20Analysis%202007-01,%20T%20Humprhreys,%20July%202007.pdf