Message-ID: <1597099.1075844473474.JavaMail.evans@thyme>
Date: Fri, 10 Nov 2000 09:16:00 -0800 (PST)
From: janine.juggins@enron.com
To: william.stuart@enron.com
Subject: Internal FX trades on EOL
Cc: dale.neuner@enron.com, susan.musch@enron.com, sara.shackleton@enron.com, 
	shane.dallmann@enron.com
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X-From: Janine Juggins
X-To: William Stuart
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William, 

I work in the London tax group and Dale has asked me to send a few lines to 
explain the position with respect to the internal FX products to be offered 
via EOL.

1. The internal FX products offered by the FX desk in London will be offered 
by RMT acting through the UK regulated agent EEFT. The activities of the FX 
desk in London are currently covered by a services agreement between EEFT and 
ENA (this will be extended to include RMT for internal trades).

2. The internal FX products offered by the FX desk in Tokyo will need to be 
offered by Enron Japan Corp KK. Note that Enron Japan Corp KK will then back 
the transactions into RMT, leaving a spread in Enron Japan Corp KK of 2.5bps. 

A couple of comments on the difference in structure between Tokyo and London 
- 
we established that a services agreement structure would not be acceptable 
for Japanese tax purposes. This is why we are recommending a back to back 
structure using Enron Japan Corp KK. We pushed the Japanese tax advisors very 
hard on this point, because this structure will also be needed for external 
trades - there are a number of knock on effects, such as potentially 
increased credit costs, more ISDAs (since external parties dealing with Tokyo 
will be dealing with Enron Japan Corp KK and not ENA).
because this is a cross border transaction the spread left in Japan needs to 
approximate the spread which would be earned by an unrelated party executing 
similar transactions - the spread of 2.5bps was provided to us by Enron Japan 
based on their review of market spreads. Note it should be possible to ensure 
that this spread rolls up to Global Markets for management reporting 
purposes, whilst leaving it in Japan for financial and legal purposes.

I can therefore confirm that for Tax all remaining questions have now been 
addressed, so there is no reason for further delay from our side. If you need 
to discuss the above further please call me in the office on 44 207 783 5326 
or on my mobile 44 77 88 43 71 95.

Regards
Janine