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Enron Mail |
Rick: We should talk about this at some point. Our international trading
business is growing by leaps and bounds, and I am trying to get systems in place to manage this BEFORE it gets totally out of control. Lisa ----- Forwarded by Lisa Yoho/NA/Enron on 05/10/2001 02:49 PM ----- Julia Murray@ECT 05/10/2001 01:34 PM To: Delmar Davis/ENRON@enronXgate, daniel.hamilton@enron.com, Ian Mccrory/ENRON@enronXgate cc: Lisa Yoho/NA/Enron@Enron Subject: Importer of Record I will follow up re the attached email with each of you. Lisa, if you have not met Del, Dan and Ian--who are responsible for EIM logistics--we should all get together to discuss the regulatory implications of our increasingly physical trading business.. Regards, Julia Julia Heintz Murray Enron Wholesale Services Enron Industrial Markets LLC 1400 Smith Street, EB3838 Houston, TX 77002 (713) 853-4794 Fax: (713) 646-3393 julia.murray@enron.com ----- Forwarded by Julia Murray/HOU/ECT on 05/10/2001 01:28 PM ----- Lisa Yoho@ENRON 05/08/2001 10:47 AM To: Julia Murray/HOU/ECT@ECT cc: Subject: Importer of Record Julia - I think this is a huge issue, and I've been trying to get to the bottom of whether or not Enron is importer of record on its trades into the US. Let's discuss when you have a minute. Thanks, Lisa ----- Forwarded by Lisa Yoho/NA/Enron on 05/08/2001 10:44 AM ----- BHafner@PGFM.com 05/07/2001 03:32 PM To: Lisa.Yoho@enron.com, dan.lyons@enron.com cc: rbelanger@pgfm.com, lyang@PGFM.com Subject: Importer of Record Lisa and Dan (and Tim): Dick Belanger and I talked about the importer of record question we discussed in this morning's telephone call. For a trading company such as Enron, that is importing products made by other companies, there is not much advantage to being importer of record. The one legal advantage is that the importer of record can challenge actions taken by the US Customs Service, such as misclassification or valuation issues. There do not appear to be other legal rights that Enron would sacrifice by not being importer of record. However, the issue may not be whether Enron should be the importer of record, but whether it can avoid being importer of record. Particularly in today's steel market, other parties may not be willing to be importer of record for exactly the reason Stelco indicated -- no one wants to expose themselves to the possibility of antidumping duties. Thus, although Enron could structure a deal in which, for example, Stelco sold to Enron Canada, and Enron sold the steel to a US customer, with that customer acting as importer of record, with the possibility of a o201 investigation and/or AD/CVD cases lurking on the horizon, the customer may not be willing to expose itself to the possibility of future AD/CVD duties, and hence would be unwilling to act as importer of record. If Enron can find someone else who is willing to act as importer of record, you would protect yourself better by structuring the deal that way. The question is whether you can find someone to be importer of record. Feel free to call if you have any questions. Regards, Betsy NOTICE: This communication may contain privileged or other confidential information. If you are not the intended recipient, or believe that you have received this communication in error, please do not print, copy, retransmit, disseminate, or otherwise use the information. Also, please indicate to the sender that you have received this communication in error, and delete the copy you received. Thank you.
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