EFTA Document EFTA01585272

Rosalia X Cracchiolo " aS hx< al low ftaafri ti From: Karen G Rortbacher Sent: Friday. March 05. 2010 10 55 AM To: Rosaka X Cracchiolo Subject. Financial Trust Corr-parry Hi Financial Trust Company says that it should use a W9 because it is an S corporation which has a single US owner. Normally you would not look ►hrough a corporation to its t.nderiying owners, but an S Corp has filed an election to do so with the IRS. However, the regulations state that only a domestic corporation can file an S Corp election, and Financial Trust is not a domestic company -- it's a non-US company because it's in the Virgin Islands. Unfortunately I didn't have the regulation in front of me during the call or I would have asked. The client is going to send what he says is his S Corp election to you, so if you could send it I can take a look and see what he's actually talking about. There's a particular exception for US Virgin Islands corporations to be taxed as American that also involves a filing, and that might be what he means. Regards K 'Karin ROCiria, Air Tax Compliance Officer I.P. Morgan Wealth Management Email Direct Line Group maiibox: PB rot mplronce tg5ciicoar 230 Disclosure Insiorgan Chase & Co and its affiliates do not txovide tax advice Accocdingty, any discussion of U.S tax matters contained herein (i-chiding any attachments) is not intended or written to be used, and cannot be used, in connection with the promotion, marketing or recommendation tiy anyone unaffiliated with IPMorgan Chase & Co. of any of the matters addressed herein or for the purpose of avoiding U.S tax related penalties Confidential Treatment Requested by JPMorgan Chase JPM-SDNY-00065231 EFTA01585272