JCX-23-09 (March 30, 2009) Tax Compliance And Enforcement Issues With Respect To Offshore Accounts And Entities: “This document, prepared by the staff of the Joint Committee on Taxation, provides background on withholding and information reporting requirements applicable to payments of U.S.-source portfolio investment income to nonresidents, the Internal Revenue Service (“IRS”) Qualified Intermediary program, the effect of bank secrecy laws and practices on U.S tax compliance and enforcement efforts involving offshore accounts, and information exchange procedures under U.S. income tax treaties and tax information exchange agreements.”