|
|
Enron Mail |
Does Jeff's explanation make any sense to you?
---------------------- Forwarded by Brent Hendry/ENRON_DEVELOPMENT on 30/09/99 12:23 PM --------------------------- From: Patricia Cini@ECT on 30/09/99 09:14 AM CDT To: Lynn Aven/ENRON_DEVELOPMENT@ENRON_DEVELOPMENT cc: Brent Hendry/ENRON_DEVELOPMENT@ENRON_DEVELOPMENT Subject: Re: Acindar Deal Lynn- This is a response from Jeff Kabel (manager at Enron Argentina) to my question regarding who was advising them on strucuturing a loan through a swap from a tax perspective? Regards, Pat ---------------------- Forwarded by Patricia Cini/HOU/ECT on 09/30/99 09:10 AM --------------------------- Jeff Kabel@ENRON_DEVELOPMENT 09/30/99 08:55 AM To: Bernardo Andrews/ENRON_DEVELOPMENT@ENRON_DEVELOPMENT cc: Patricia Cini/HOU/ECT@ECT, Federico Cerisoli/ENRON_DEVELOPMENT@ENRON_DEVELOPMENT, John J Shoobridge/ENRON_DEVELOPMENT@ENRON_DEVELOPMENT Subject: Re: Acindar Deal Though termed "dummy swap" for internal discussions it is actually an out-of-the-money swap for Enron. That is, to ensure that Acindar repays the loan through the compensating in-the-money purchase of power in 2003 (with no payments from them before this time) we need to structure the swap starting in 1999 in this way. Andersen has advised us of the tax implications of various financial "risk managment" structures and loans, this one qualifying as the former with no withholding tax levied. Jeff Bernardo Andrews 09/30/99 11:37 AM To: Patricia Cini/HOU/ECT@ECT cc: Federico Cerisoli/ENRON_DEVELOPMENT@ENRON_DEVELOPMENT, Jeff Kabel/ENRON_DEVELOPMENT@ENRON_DEVELOPMENT, John J Shoobridge/ENRON_DEVELOPMENT@ENRON_DEVELOPMENT Subject: Re: Acindar Deal We are being advised by Arthur Andersen. We are diiscussing with them on all tax and swap design issues (on taxation purposes). Best Regards, Bernardo To: Bernardo Andrews/ENRON_DEVELOPMENT@ENRON_DEVELOPMENT cc: Subject: Re: Acindar Deal Bernardo- Who was advising you on the tax issues of this deal and making the recommendation to set up "dummy swaps"? Regards, Pat
|