Subject: Re: Conference Call Tuesday 25 May 1999
From: [email-masked]
To: [email-masked]
Cc: [email-masked]
Date: Mon, 24 May 1999 14:44:00 -0700 (PDT)

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