date: Mon May 16 15:28:48 2005
from: Phil Jones <p.jones@uea.ac.uk>
subject: More from Battelle
to: tcrowley@duke.edu, Gabi Hegerl <hegerl@duke.edu>

    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" <angela.saraceno@pnl.gov>
     Subject: RE: Some more thoughts on the payments
     To: Phil Jones <p.jones@uea.ac.uk>
     Cc: "Frankenfield, Mindy K" <mindy.frankenfield@pnl.gov>,
      "Robertson, Teresa L" <Teresa.Robertson@pnl.gov>,
      "King, Onie L" <onie.king@pnl.gov>
     Thread-Topic: Some more thoughts on the payments
     thread-index: AcVSNEyds/yKeWYHQ9asFUHpfZW7bACdBJ/g
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     <?xml:namespace prefix = o ns = "urn:schemas-microsoft-com:office:office" />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" <WildingC@ustax.co.uk>
          To: <p.jones@uea.ac.uk>
          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)
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          School of Environmental Sciences    Fax +44 (0) 1603 507784
          University of East Anglia
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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
     ----------------------------------------------------------------------------

