Can't remember if I ever shared this with you two.  (Michelle, Dusty sent this following one of the GSP conversations)

 -----Original Message-----
From: 	"Burke, Dusty" <dburke@velaw.com>@ENRON [mailto:IMCEANOTES-+22Burke+2C+20Dusty+22+20+3Cdburke+40velaw+2Ecom+3E+40ENRON@ENRON.com] 
Sent:	Tuesday, June 19, 2001 6:21 PM
To:	Barrow, Cynthia
Subject:	Leased Employee Memorandum


Cynthia:  Attached (for  your reading enjoyment when you are REALLY bored) is a memorandum summarizing  the "leased employee rule" under section 414(n) of the Internal Revenue  Code.  As I mentioned, the "recordkeeping exception" outlined in the memo  and in the attached chart (if you meet the requirements) will keep you from  having to track leased employees, related hours, etc.  In addition, the  recordkeeping exception gets you out of the requirement to grant participation  and vesting service credit in the case of any temp/contractor who is later hired  by Enron as a regular employee, which you otherwise have to do.  Let me  know if you have any questions.  Dusty  Burke.   
Miriam M. (Dusty) Burke 
Vinson  & Elkins L.L.P. 
One American Center 
600 Congress Avenue, Suite 2700  
Austin, TX 78701 
(512) 495-8425; (713) 758-3558 (telephone) 
(512)  236-3411 (fax) 
dburke@velaw.com  
 
 - Leased Employee Rule - Internal Revenue Code Section 414(n).DOC