Ok, I have a question that has been bothering me for a while now, and I hope someone here can help me with it...

(keep in mind that "documentary evidence" here has nothing to do with CIP!)

IRS Publ 515 Withholding of Tax on Nonresident Aliens and Foreign Entities states on page 10, column 3, under "Documentary Evidence: Establishment of foreign status":
You have reason to know that documentary evidence is unreliable or incorrect to establish a direct accountholder's status as a foreign person if:
(yadda yadda)
2) You have a mailing address or residence address for the account holder in the United States or if the account holder notifies you of a new address in the United States, or
(yawn)
(yadda yadda)
You may, however, rely on documentary evidence as establishing an account holder's foreign status if any of the following apply.
1) If the mailing or residence address is in the United States, you receive the documentary evidence from an individual, and
(yadda yadda)
b)You possess or obtain a Form W-8 that contains a permanent residence address and mailing address outside the United States (or if a mailing address is inside the United States the account holder provides a reasonable explanation, in writing, supporting the account holder's foreign status, or the Form W-8 was received before December 31, 2001), or
(bored now)
(yadda yadda)

.... Ok - the part I'm interested in is the last paragraph (italics added). If we have a NRA who has a foreign permanent address but a mailing address inside the US - and most of ours do - should we be having them make a written statement explaining why they have a US mailing address?

I'd like to hear how everyone else is handling these.... Suggestions for formats of the written explanation, etc. If their explanation isn't "good enough", do you deny the account? What constitutes "good enough"?

Needless to say, we haven't been following this even though it's been out since 2002... But I can always pull my list of new W-8's since 1/1/02 and send out form letters requesting the info.