Subject: Re: Change of pulp description
From: [email-masked]
To: [email-masked]
Cc: [email-masked], [email-masked]
Date: Thu, 27 Apr 2000 04:37:00 -0700 (PDT)

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