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Enron Mail |
Mark, sorry we have not been able to connect since you have been in Brazil.
I concur with your summary of the tax issue below and, if the facts are as you posit, we would need to implement a cost sharing arrangement to address the tax exposure raised by having a person located in London who acts on behalf of ENA and, even at that, there may be additional concerns that would have to be addressed. Separately, I have spoken with Jeff Blumenthal regarding the Singapore domain name issue and, in general, believe that we should be able to have ECTS acquire the domain name (which, from my discussion with Jeff, I understand is required due to Singapore rules requiring such names only be held by Singaporeans) and cross-charge ENA for the expense associated with it. In this fashion, we place the costs of EOL's forage into Singapore with ENA who, in turn, allocates such charge to the participants of EOL via the EOL Cost Sharing Agreement. Finally, Jeff has contacted Janine Juggins in London regarding an assessment of the tax presence issues raised by ECTS's acquisition, and EOL's use, of a domain name in Singapore but my initial reaction is that such activity should not present any significant Singapore tax nexus issues - we will follow up with you on this after Janine is able to solidify our advice on the matter. I hope all is well with you in Brazil and look forward to speaking with you soon. Best regards. To: Bob Crane/HOU/ECT@ECT cc: Stephen H Douglas/HOU/ECT@ECT, Jeff Blumenthal/HOU/ECT@ECT, Dale Neuner/HOU/ECT@ECT Subject: Re: Change of pulp description I have no objection to changing the product name. The tax issue concerns the location of the trader - if the guy managing the prices is in London but the transactions are with ENA, there may be tax implications. Mark Bob Crane 04/25/2000 08:35 AM To: Mark Taylor/HOU/ECT@ECT, Dale Neuner/HOU/ECT@ECT cc: Subject: Change of pulp description Mark, I have not yet been contacted by legal/tax regarding the change of description for PIX indices. We still basically want only to delete "US" and replace it with "PIX". To my simplistic, non-legal, mind this is a pretty simple issue....can't we just do it?? Bob
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