date: Mon May 16 15:28:48 2005 from: Phil Jones subject: More from Battelle to: tcrowley@duke.edu, Gabi Hegerl Gabi, Tom, Here's the last thing I got on May 9 from the people at PNL. I'm away from later today until Friday, so no rush. But if you are going to talk to Anjuli, can you ask her to give us all clearer instructions. The process they are saying we need to go through will take months. It applies to Nathan as well. I've not heard from Myles So any help would be appreciated. Apologies if this is a pain. Cheers Phil Date: Mon, 09 May 2005 08:07:06 -0700 From: "Saraceno, Angela M" Subject: RE: Some more thoughts on the payments To: Phil Jones Cc: "Frankenfield, Mindy K" , "Robertson, Teresa L" , "King, Onie L" Thread-Topic: Some more thoughts on the payments thread-index: AcVSNEyds/yKeWYHQ9asFUHpfZW7bACdBJ/g X-MS-Has-Attach: X-MS-TNEF-Correlator: X-OriginalArrivalTime: 09 May 2005 15:07:07.0243 (UTC) FILETIME=[C42CB3B0:01C554A8] X-Spam-Score: 0.1 X-Spam-Level: / Hi Dr. Jones, I asked our corporate tax attorney whether or not your reimbursements could be considered foreign source income, and she said that they could not. So, you will have to follow the previously discussed procedure regarding these payments. Please let me know if you have any additional questions. Thanks, Angela From: Phil Jones [[1]mailto:p.jones@uea.ac.uk] Sent: Friday, May 06, 2005 5:02 AM To: Saraceno, Angela M Cc: Frankenfield, Mindy K; Robertson, Teresa L; King, Onie L Subject: Some more thoughts on the payments Dear Angela, I've been making a few enquiries here in the UK about how to get an ITIN number. According to the IRS web pages I can apply at the embassy, or through three different companies based in London. I contacted one of these and outlined the issues from your emails over the phone. The person asks (see their email below) that I contact you again. His suggestion is to treat reimbursements as 'foreign source' similar to payments already received in 2003. Can you look into this and give me your thoughts? I am away much of the next two weeks, so there is no rush to reply. The costs he refers to come to about £400, so not cheap. Going through the embassy would be much cheaper, but harder to arrange. Looking forward to hearing from you when I get back. I will be at work on Monday week (May 16) but just for the one day. Regards Phil Subject: US Taxpayer Identification Number Date: Fri, 6 May 2005 11:39:04 +0100 From: "Chris Wilding" To: X-Spam-Score: 0.1 X-Spam-Level: / Dear Professor Jones Further to our telephone conversation on Tuesday, I have discussed your issue with a colleague. We feel that the IRS would probably regard the reimbursement of travel expenses as sufficient reason to issue an ITIN, and so you could then use the forms you have been sent to release the payment. This would obviously cost time and money to resolve. Alternatively, there may well be some mileage in contacting the US company and asking them to treat the reimbursements as "foreign source", similar to other payments you have received, because they relate to the work you performed in the UK for them. This would remove the need for the ITIN and treaty claim. There may also be other arrangements you can make with the US company to avoid unnecessary costs and form-filling. In practical terms there is no question of any tax avoidance as you have indicated that amounts are being reported to the UK Inland Revenue and the payments would be exempt from US tax under the US/UK treaty in any event. We would of course be very happy to assist you with the ITIN application if that is the only way around this problem. I hope this is of use. If you do end up requiring our help with the ITIN please do not hesitate to contact me. Regards Chris Wilding ---------------------------------------------------------------------- Chris Wilding wildingc@ustax.co.uk Direct dial +44 (0)20 7556 1423 Secretary +44 (0)20 7556 1405 (Sara Metcalf) ------------------------------------------------------------------------------------ -- Buzzacott Livingstone, 12 New Fetter Lane, London, EC4A 1AG Tel +44 (0)20 7556 1400 Fax +44 (0)20 7556 1212 The information in this e-mail is confidential and may be legally privileged. It is intended solely for the addressee. If you are not the intended recipient, any disclosure, copying, distribution or any action taken or omitted to be taken in reliance on it, is prohibited and may be unlawful. This e-mail has been created and transmitted by an automated system and may therefore not be endorsed by a duly authorised signatory. When addressed to our clients any opinions or advice contained in this e-mail are subject to the terms and conditions expressed in the governing Buzzacott Livingstone engagement letter. Prof. Phil Jones Climatic Research Unit Telephone +44 (0) 1603 592090 School of Environmental Sciences Fax +44 (0) 1603 507784 University of East Anglia Norwich Email p.jones@uea.ac.uk NR4 7TJ UK ---------------------------------------------------------------------------- Prof. Phil Jones Climatic Research Unit Telephone +44 (0) 1603 592090 School of Environmental Sciences Fax +44 (0) 1603 507784 University of East Anglia Norwich Email p.jones@uea.ac.uk NR4 7TJ UK ----------------------------------------------------------------------------