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Enron Mail |
Sara,
we are currently working with John to establish a corporate structure for equities trading out of London. I am due to meet with him today or tomorrow so will follow up on these particular trades. Regards Janine To: Sara Shackleton/HOU/ECT@ECT cc: Janine Juggins/LON/ECT@ECT, Jordan Mintz/HOU/ECT@ECT Subject: Re: Instinet Corporation Thanks for being on top of this. As I mentioned in my voice mail to you on Friday, no trader should conclude a transaction on behalf of ENA while located in a foreign country. On several discrete occasions we have sanctioned exceptions to this rule but each such case had unique facts that permitted us to conclude that those transactions were OK. Further, any physical presence by ENA is a foreign country is generally a bad idea because it supports a foreign tax authority's argument that ENA is doing business in their country. Thus, because of that general concern, no Instinet terminal should be put in place on behalf of ENA in a foreign country (especially since for what purpose would such a thing be used - trading?) but, rather, an appropriate foreign affiliate of Enron should contract for such service (in this respect, you should speak with Janine Juggins in our London tax group - Janine is our resident trading tax expert in London and will be very familiar with the things described in this E-mail). I will be out of the country this week (returning the week of the 18th) and can be reached at the Vancouver Hotel in Vancouver, British Columbia. Best regards. Steve. From: Sara Shackleton on 09/08/2000 04:46 PM To: John Greene/LON/ECT@ECT cc: Stephen H Douglas/HOU/ECT@ECT, Jeff Blumenthal/HOU/ECT@ECT Subject: Instinet Corporation John: I hear that you are trying to trade in the name of Enron North America Corp. while you sit in London. Althought both ECT Investments, Inc. and Enron North America Corp. have agreements with Instinet Corporation, those companies are all U.S. companies without any presence in the U.K. (those companies do not pay U.K. taxes!) I have asked the ENA tax lawyers to review the implications of your proposed activity. I will try to speak with you Monday before things go too far. Please provide an immediate response and copy the tax lawyers noted above. Thanks. Sara
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