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Enron Mail |
Sara, Janine Juggins is a tax person in our London office. I am forwarding a
chart she sent me, which Trena would like to discuss at our meeting. -- Bob Robert E. Bruce Senior Counsel Enron North America Corp. T (713) 345-7780 F (713) 646-3393 robert.bruce@enron.com ----- Forwarded by Robert Bruce/NA/Enron on 02/06/2001 09:20 AM ----- Janine Juggins@ECT 02/02/2001 08:17 AM To: Janine Juggins/LON/ECT@ECT cc: Trena McFarland/NA/Enron@Enron, Sheila Glover/HOU/ECT@ECT, Robert Bruce/NA/Enron@Enron, Morris Richard Clark/HOU/ECT@ECT, Catharina Clabots/LON/ECT@ECT, Stephen H Douglas/HOU/ECT@ECT Subject: Re: Softs structure Attached is the legal structure chart referred to in the mail below. Also, further to Trena's mail yesterday if because there is a requirement to use a single legal entity as principal only alternatives A and B will be considered, the recommendation would be to use Enron Softs Inc and not ENA. This is because of the additional tax exposure which would potentially attach to the income generated by other businesses in ENA. A decision not to use a separate legal entity in the UK (alternative C ) attracts a tax disbenefit. I will estimate the tax costs/benefits of the alternatives A thru C so that they can be factored into the overall cost/benefit analysis. Do you have an estimate of the net income before tax which will be earned by the Softs business, split between NY activity and London activity ? Maybe this can be taken from the budgets for 2001 ? Regards Janine Janine Juggins 01/02/2001 17:49 To: Trena McFarland/NA/Enron@Enron, Sheila Glover/HOU/ECT@ECT, Robert Bruce/NA/Enron@Enron cc: Morris Richard Clark/HOU/ECT@ECT, Catharina Clabots/LON/ECT@ECT Subject: Softs structure Attached is a (very) draft note discussing the various alternative structures addressed during various telephone calls. It is far from finalised, but I thought it would be a good idea to circulate it now to get some further feedback. Note that Morris and Catharina have not yet had the opportunity to review and comment on the draft. I will follow up with a corporate structure chart tomorrow so that it is clear where all the entities sit within our corporate structure. My view is that it is preferable to use EFET LLC for the London based activity and ENA for the NY based activity. I have not referred at all to ECTRIC because this entity will be effectively replaced over time by EFET LLC. Regards Janine
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