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Enron Mail |
Thanks for this and agreeing to attend (my office).
CRC was Paul Waine's baby and no counterparty has agreed to it. It's complex and not a real flyer. My preference would be to live with the tax risk if you can bear it and put in place the back-to-backs. EEFT can arrange for anyone (including Sempra!). Until tomorrow. Paul Janine Juggins 05/24/99 02:04 PM To: Paul Simons/LON/ECT@ECT cc: Subject: Re: Conference Call Tuesday 25 May 1999 Paul, I am happy to attend - I assume your office ? I had a quick chat with Paul Wallace, as far as I can see this "informal procedure" has been put in place to achieve the effect of credit consolidation. I wonder whether in fact bona fide credit consoldiation could be put in place to deal with Sempra and Dapsa (an Argentinian counterparty where the same things happen). This would involve, ECTRI doing the deal with Sempra, the deal then being automatically novated to ECT Houston, with a back to back to ECTRI. ECT Houston would bear the credit risk (and be compensated at arm's length for this) and ECTRI would have the same economics as the original transaction with Sempra. With the informal procedure as it stands, there is the risk that ECT Houston could have a PE in the UK (UK tax presence), although providing that the swap back to ECTRI is respected the amount of the income subjected to UK tax ought to be just the compensation for the credit risk. However on the other hand there is also the wider concern that other ECT Houston activities may get attributed to the UK PE (such as the currency desk). Presumably from a regulatory perspective EEFT can act as arranger for ECT Houston ??? Regards Janine Paul Simons 24/05/99 13:37 To: Janine Juggins/LON/ECT@ECT cc: Subject: Conference Call Tuesday 25 May 1999 I'll need you or a nominee to attend this one, please, to advise on tax --thks ---------------------- Forwarded by Paul Simons/LON/ECT on 05/24/99 01:41 PM --------------------------- Nicola Beales 05/21/99 04:48 PM To: Paul Simons/LON/ECT@ECT cc: Subject: Conference Call Tuesday 25 May 1999 Faye Ellis called to arrange a conference call for Tuesday. I put it in your diary for Tuesday afternoon 4.30pm London time. The conference call is with Sara Shackleton, Morris Clarke, Steve Douglas and it is regarding Sempra & Regulatory Issues. They will call you. Kim
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