This excerpt taken from the ATVI 10-K filed Jun 14, 2007.
The Companys tax equalization policy will apply during your assignment. The policy essentially keeps you in the same tax position as if you had remained in the US. Hypothetical tax, which will be calculated in a manner similar to actual US Federal and California income tax, will be withheld from your monthly pay via US payroll.
You will pay hypothetical tax on compensation items that you would have received had you remained in the US. These items include, but are not limited to base salary, bonus, stock option income, etc.
The Company will pay the tax on all other items of compensation mentioned in this letter. The Company shall also be responsible for the UK income tax liability on all items of Company compensation.
Activision, Inc. will use the services of Deloitte to prepare your UK and applicable US income tax returns. The Company will pay the cost of this service.
The Company will also pay for the services of Deloitte to administer all aspects of your international assignment. Your primary Deloitte contact is Eva Blanc, who can be reached at 408-704-2587; email@example.com.
Please note, if you leave the Company on a voluntary basis and in breach of your Employment Agreement within one year of your relocation to the UK, you will be required to reimburse Activision, Inc. for 100% of all one-time relocation expenses incurred by the Company. Should you leave on a voluntary basis and in breach of your Employment Agreement within the second year of your relocation, you will be required to repay 50% of all relocation expenses incurred by the Company.
Activision, Inc. will pay the costs associated with your repatriation back to California, US (e.g. airfare, household goods, temporary living, etc.), provided you either remain employed by the Company or be involuntarily terminated by the Company at the time of the repatriation.
In order to acknowledge your voluntary acceptance of this assignment, please sign and date this document and return it to me. Changes to this letter, your employment status, and your international assignment are only effective if they are in writing and signed by me. I wish you the very best with your assignment in the UK.
Sr. Director, Global Compensation & Benefits
cc: Heather Rangel, Deloitte Tax LLP
Jeff Adams, Deloitte Tax LLP