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
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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:
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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)
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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
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