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I am not aware of any services associated with EnronOnline which the Japanese
office might provide which could be the subject of such fees. Dave Susan Musch@ENRON_DEVELOPMENT 05/01/2000 06:17 PM To: Mario Parra Cardoso/Corp/Enron@ENRON cc: Jeff Blumenthal/HOU/ECT@ECT@ENRON, Stephen H Douglas/HOU/ECT@ECT@ENRON, David Forster/Corp/Enron@Enron, Alan Aronowitz@ECT, Mark Taylor@ECT Subject: Re: Japan, Argentina and Brazil Mario, Yes, we should be ready to go, although the law firm we are using in Japan (Baker & McKenzie in Tokyo) have indicated that they still have a few open issues to follow-up on. Baker & McKenzie have concluded that where an Enron non-Tokyo trading office receives a payment on a swap from a Japanese counterparty, that payment should not be subject to Japanese income tax or withholding tax. Further, they have advised that consumption tax (Japan's 5% VAT) should not apply to financial transactions, although Japanese counterparties acquiring physical product for delivery in Japan would be subject to the 5% consumption tax. Baker & McKenzie have advised that they need to do some follow-up work with respect to payments from options and from physical contracts as well as some further checking on the tax treaties that Japan has with the countries where our non-Japan trading offices are located. I expect to have their response shortly. One issue that we are currently pursuing is the Japanese tax consequences of the Enron Japan trading office providing services that benefit the other Enron trading offices. In this case, it may be appropriate for Enron Japan to receive a service fee for such services. I am in the process of determining to what extent Enron Japan would be providing services. Please let me know if you have any questions or need any additional information. I will let you know of any additional developments as soon as they occur. Best regards, Susan Mario Parra Cardoso@ENRON 05/01/2000 02:50 PM To: Susan Musch/ENRON_DEVELOPMENT@ENRON_DEVELOPMENT cc: Jeff Blumenthal/HOU/ECT@ECT, Stephen H Douglas/HOU/ECT@ECT, David Forster/Corp/Enron@Enron Subject: Re: Japan, Argentina and Brazil Susan, Following up on David's email, I understand we are ready to go, right? Mario ---------------------- Forwarded by Mario Parra Cardoso/Corp/Enron on 05/01/2000 02:39 PM --------------------------- David Forster 04/27/2000 06:28 PM To: Susan Musch/ENRON_DEVELOPMENT@ENRON_DEVELOPMENT cc: Mario Parra Cardoso/Corp/Enron@Enron, Jeff Blumenthal/HOU/ECT@ECT, Stephen H Douglas/HOU/ECT@ECT Subject: Re: Japan, Argentina and Brazil Mario is away until next week. The Japanese could trade with any Enron office which is posting commodities on EnronOnline - but are most likely to be interested primarily in the products posted by Singapore (global products), as it provides the best timezone overlap. Both physical and financial are possible, but none of the physical delivery locations on EnronOnline are currently in Japan. Dave Susan Musch@ENRON_DEVELOPMENT 04/27/2000 12:38 PM To: Mario Parra Cardoso/Corp/Enron@ENRON cc: Jeff Blumenthal/HOU/ECT@ECT@ENRON, Stephen H Douglas/HOU/ECT@ECT@ENRON, David Forster/Corp/Enron@Enron Subject: Re: Japan, Argentina and Brazil Mario, Thanks for your e-mail. I wanted to follow up on one more point just to make sure we have everything covered for May 1st. Do we expect the Japanese to do online trading with the other Enron trading offices? If so, which offices would they be trading with and what kind of products would be traded? For example, would there be physical settlement (or delivery) of product in Japan to the Japanese customers or would there be only financial derivatives traded? I really appreciate your help on this. Best regards, Susan Mario Parra Cardoso@ENRON 04/27/2000 10:55 AM To: Susan Musch/ENRON_DEVELOPMENT@ENRON_DEVELOPMENT cc: Jeff Blumenthal/HOU/ECT@ECT, Stephen H Douglas/HOU/ECT@ECT, David Forster/Corp/Enron@Enron Subject: Re: Japan, Argentina and Brazil Susan, Your understanding is correct. Thanks, Mario Parra Cardoso EnronOnline Susan Musch@ENRON_DEVELOPMENT 04/27/2000 10:46 AM To: Mario Parra Cardoso/Corp/Enron@ENRON cc: Jeff Blumenthal/HOU/ECT@ECT@ENRON, Stephen H Douglas/HOU/ECT@ECT@ENRON Subject: Re: Japan, Argentina and Brazil I have a conference call set up with our Japanese tax counsel this evening (Thursday evening Houston time). After the call, I should be able to confirm that there are no major Japanese tax issues once our Japan office commences trading with Japanese counterparties through Enron Online. However, I understand that initially, the Japan Online implementation will only entail Japanese counterparties trading internationally (e.g. trading non-Japanese products). Based on this assumption, I think we're okay for Monday from a Japanese trading office perspective. Please let me know if my understanding is incorrect. Best regards, Susan Mario Parra Cardoso@ENRON 04/26/2000 03:34 PM To: Jeff Blumenthal/HOU/ECT@ECT cc: Susan Musch/ENRON_DEVELOPMENT@ENRON_DEVELOPMENT, Stephen H Douglas/HOU/ECT@ECT Subject: Re: Japan, Argentina and Brazil Jeff, The marketing material is on its way to Tokyo. This Friday it is expected to be sent to clients. As you can see, time is something that we don't have. Could you please let us know if we are OK to go with the Japanese launch? Thanks, Mario ---------------------- Forwarded by Mario Parra Cardoso/Corp/Enron on 04/26/2000 03:27 PM --------------------------- Mario Parra Cardoso 04/19/2000 03:30 PM To: Jeff Blumenthal/HOU/ECT@ECT cc: Susan Musch/ENRON_DEVELOPMENT@ENRON_DEVELOPMENT@ECT, Stephen H Douglas/HOU/ECT@ECT Subject: Re: Japan, Argentina and Brazil Jeff, You are right. For the launch of EnronOnline in Japan, local clients will be offered the ability to trade existing EOL products. Japanese products will be offered in the future. Please be advised, though, that Singapore products are likely to be added to EnronOnline before the Japanese launch. We expect Japanese clients to trade Singapore products, in addition to the ones currently available. Thanks, Mario Jeff Blumenthal@ECT 04/19/2000 03:18 PM To: Mario Parra Cardoso/Corp/Enron@ENRON cc: Susan Musch/ENRON_DEVELOPMENT@ENRON_DEVELOPMENT, Stephen H Douglas/HOU/ECT@ECT Subject: Re: Japan, Argentina and Brazil Mario, We have begun discussions with a Tokyo law firm regarding the various Japanese tax issues related to EnronOnLine. In that vein, can you please clarify whether ENA will be offering certain Japanese counterparties the ability to trade existing EOL products (i.e., products that are not Japanese-based) and that such offering will commence in May, 2000, while no Japanese products will be offered until sometime in the future? If you would, please reply to all listed above so that we can hold discussions this evening with out Japanese tax advisors. Thanks for your help, and best regards, Jeff Mario Parra Cardoso@ENRON 04/19/2000 10:12 AM To: Jeff Blumenthal/HOU/ECT@ECT cc: Stephen H Douglas/HOU/ECT@ECT Subject: Re: Japan, Argentina and Brazil Jeff, Japan is obviously the country that worries me the most since we intend to launch the site for Japanese clients in May. The marketing material is expected to be sent by late next week. Please let me know how long the process for Japan may still last and if you anticipate problems. Brazil and Argentina are expected be launched this summer. Thanks, Mario Jeff Blumenthal@ECT 04/19/2000 09:34 AM To: Mario Parra Cardoso/Corp/Enron@ENRON cc: Stephen H Douglas/HOU/ECT@ECT Subject: Re: Japan, Argentina and Brazil Mario, We've begun working with our outside tax advisors. I understand the urgency of this matter and will see that it is moved along as quickly as possible. In the meantime, please let me know if you have any questions. Thanks. Mario Parra Cardoso@ENRON 04/17/2000 04:07 PM To: Jeff Blumenthal/HOU/ECT@ECT cc: Subject: Japan, Argentina and Brazil Jeff, Anything new on tax issues related to EnronOnline for the countries above mentioned? Thanks, Mario
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