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Enron Mail |
Jeff: I'll call you later. Sara
Sara Shackleton Enron North America Corp. 1400 Smith Street, EB 3801a Houston, Texas 77002 713-853-5620 (phone) 713-646-3490 (fax) sara.shackleton@enron.com ----- Forwarded by Sara Shackleton/HOU/ECT on 01/18/2001 09:33 AM ----- Peter Russell@ENRON 01/17/2001 09:14 AM To: Sara Shackleton/HOU/ECT@ECT cc: Subject: Re: "ECT Europe Accounting" as ENA hedge counterparty Sara I am not sure I understand the question. What do you mean by RMT? Here is an explanation of what happened here in London: Due to cash flows originated by tax in London before year end, some Enron Europe companies had FX positions that needed to be hedged. However, due to tax reasons we could not hedge the FX positions in the entities in which they arose because the hedge gains or losses would be subject to the 'sub-part F' income rules (and liable to double tax). Tax therefore suggested that we transact the hedges in the name of 'ECT Europe Accounting Entity' (company 912), where they would be consolidated into Enron Europe for management accounting but would be within a US legal entity and therefore not subject to double tax. My understanding is that 912 is a branch of ENA and therefore there is a hedge transacted between ENA 912 and ENA. We have been trying to identify the hedges within company 912 but cannot see them there. Can you help with this? Regards Peter From: Sara Shackleton@ECT on 17/01/2001 09:00 CST To: Jeff Blumenthal/HOU/ECT@ECT, Peter Russell/EU/Enron@Enron cc: Laurel Adams/HOU/ECT@ECT Subject: "ECT Europe Accounting" as ENA hedge counterparty Jeff and Peter: Has this question been resolved? Please let me hear from you. We need to make certain that these transactions are properly booked. Thanks. Sara Sara Shackleton Enron North America Corp. 1400 Smith Street, EB 3801a Houston, Texas 77002 713-853-5620 (phone) 713-646-3490 (fax) sara.shackleton@enron.com ----- Forwarded by Sara Shackleton/HOU/ECT on 01/17/2001 08:58 AM ----- Sara Shackleton 01/10/2001 09:50 AM To: Jeff Blumenthal/HOU/ECT@ECT cc: Subject: "ECT Europe Accounting" as ENA hedge counterparty Jeff: Do you have an answer yet? Sara Sara Shackleton Enron North America Corp. 1400 Smith Street, EB 3801a Houston, Texas 77002 713-853-5620 (phone) 713-646-3490 (fax) sara.shackleton@enron.com ----- Forwarded by Sara Shackleton/HOU/ECT on 01/10/2001 09:49 AM ----- Sara Shackleton 01/03/2001 01:08 PM To: Jeff Blumenthal/HOU/ECT cc: Subject: "ECT Europe Accounting" as ENA hedge counterparty Jeff: In connection with the instructions given by London to Shane Dallmann, note that the instruction for ENA to transact the Euro hedges was given by Peter Russell. Please advise as to whether these should be RMT transactions and which Enron affiliate should be involved. Thanks. Sara
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