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Enron Mail |
Sorry. I forgot to include you the first time. Also, please let me know if
you have any questions regarding the tax language contained in the margin agreement that we discussed last week. Best regards. ---------------------- Forwarded by Jeff Blumenthal/HOU/ECT on 07/10/2000 07:16 PM --------------------------- Jeff Blumenthal 07/10/2000 03:31 PM To: Jaime Williams/NA/Enron@ENRON, Agustin Perez/NA/Enron@ENRON, Mark Taylor/HOU/ECT@ECT, Stephen H Douglas/HOU/ECT@ECT, David Forster/Corp/Enron@Enron, Leonardo Pacheco/Corp/Enron@Enron, Carol St Clair/HOU/ECT@ECT cc: Subject: EOL -- Mexican tax consequences This e-mail sets forth the Mexican tax consequences arising from Enron North America Corp. (or any other United States entity that is wholly-owned by Enron Corp. and does not have nexus in Mexico) ("ENA") entering into any of the sixteen financial derivative transactions described in the "Hedging Indexes definitions" tab contained in the attachment below ("Transactions") with Mexican counterparties through EnronOnline ("EOL"). (The Transactions are those that Jaime Williams has indicated are most likely to be entered into with Mexican counterparties. Although such counterparties may enter into any of the Transactions, they may also transact through EOL with respect to any other product offered. I will follow up as soon as possible regarding the Mexican tax consequences applicable to those products not addressed in this e-mail.) Based on advice received from Chevez, Ruiz, Zamarripa y Cia., S.C. (our Mexican tax counsel based in Mexico City), payments made by a Mexican counterparty to ENA pursuant to any of the Transactions will not be subject to Mexican income, withholding or value-added tax. Consequently, the Transactions (described in the attachment below) are approved by the ENA Tax Department for trading through EnronOnline with Mexican counterparties. Jaime and Agustin: Please keep in mind that our previous discussions regarding ENA's activities in Mexico (i.e., that its activities in Mexico should continue to be limited such that it is not subject to Mexican tax) also apply to ENA's EOL transactions with Mexican counterparties. Thus, Enron employees' activities in Mexico on behalf of ENA (or any other non-Mexican Enron entity), whether through EOL transactions or otherwise, should be limited to general marketing of Enron products; no negotiations regarding any product should take place in Mexico on behalf of ENA, and no contract should be executed in Mexico on behalf of ENA. Please contact me at 713.853.5777 with any questions. Best regards, Jeff Jaime Williams@ENRON 06/13/2000 08:18 PM To: Jeff Blumenthal/HOU/ECT@ECT cc: Mario Parra Cardoso/Corp/Enron@Enron, Susan Helton/HOU/ECT@ECT, Alberto Carreno/NA/Enron@ENRON, Rod Nelson/HOU/ECT@ECT, Carol St Clair/HOU/ECT@ECT, Sara Shackleton/HOU/ECT@ECT Subject: EOL list Jeff, I am sending you the specific information of the indexes and products that we believe our customers would be trading on EOL.....Please take a look at the file attached, and the page with Index Definitions, for the information you are looking for. The trades will be performed based on indexes taht already exist in OEL, so no new Mexican Indices will be included. Please note however, that the mexican gas is priced in Mexico on the basis of the Tetco/Valero basket. So, most probably, that same basket will be included in the system to accomodate to our customer's needs. Please note that Carol St Clair will be helping us on the legal aspects of including Mexico into the EOL system. Thanks and regards. ---------------------- Forwarded by Jaime Williams/NA/Enron on 06/13/2000 05:37 PM --------------------------- Alejandro Montemayor 06/13/2000 03:32 PM To: Jaime Williams/NA/Enron@ENRON cc: Subject: EOL list Jaime Aqui te mando el archivo de la lista de clientes EOL, en el mismo archivo ya esta la descripci?n de cada uno de los productos. Son tres los productos que no estan en EOL: el promedio Tetco y PG&E; el poliestireno y el PET. Por otro lado para el polietileno esta la descripci?n para el LLDPE. Si se requiere alg?n cambio solo avisame. Saludos Alex
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