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Enron Mail |
FYI.
----- Forwarded by Alan Aronowitz/HOU/ECT on 09/25/2000 05:49 PM ----- Susan Musch@ENRON_DEVELOPMENT 09/24/2000 08:40 PM To: Paul.TYO.Davis@BakerNet.com, Edwin.T.Whatley@BAKERNET.com cc: jane.mcbride@enron.com, john.viverito@enron.com, Jeremy.Pitts@bakernet.com(eMail), Alan Aronowitz@ECT Subject: Re: Trader Paul and Ed, I want to confirm my understanding of your advice from last week (attached below). I think you're advising consistent with what Ed had advised back in June, but I'm not totally sure. That is, it would be best to have back-to-back trades between Enron Japan ("EJ") and Enron North America ("ENA"). Under this scenario, DD would be an EJ employee who would enter into the trades for EJ as principal. Then, EJ would enter into mirror trades with ENA. The issue, as I understand it, under this scenario is that the NTA could assert transfer pricing issues if the trades between EJ and ENA weren't at arms' length. Would you please confirm that this is your conclusion on how the trades should be structured? I am trying to get this structure resolved by Monday night (Houston time) so I would appreciate your thoughts in an e-mail during your Monday. Best regards, Susan Paul.TYO.Davis@BakerNet.com on 09/21/2000 04:58:44 AM To: Susan.Musch@enron.com cc: jane.mcbride@enron.com, john.viverito@enron.com, Jeremy.Pitts@BAKERNET.com, Edwin.T.Whatley@BAKERNET.com Subject: Trader Dear Susan Jane and John asked us to send you the attached notes on a discussion we had today concerning ENA's financial trader in Tokyo. You may also wish to refer to Ed's original June 23 advice on the subject. We look forward to assisting with the structuring of the arrangements in due course. Regards Paul Davis <<Memo 00.09.21.doc<< ------------------------------------------------------------------------------ -- -------- This is an e-mail from Baker & McKenzie - Tokyo Aoyama Law Office (Qualified Joint Enterprise Offices). The contents of this e-mail may be privileged and confidential and are intended only for the use of the addressee. No one else may copy, forward, disclose or use all or any of it in any form. If you are not an intended recipient, please notify us immediately (by reply e-mail) and delete this e-mail from your system. Thank you - Memo 00.09.21.doc
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