David,  In Hong Kong and Japan, we set up local entities and used those 
entities to apply for the various licenses in those jurisdictions.  I assumed 
we would do the same in Singapore.  However, I think our discussions over the 
past two weeks have raised questions about which entities will be used for 
bandwidth trading in Asia.  There now appears to be a question about using 
one trading entity, wherever it may be domiciled, and getting that company 
licensed in each jurisdiction.  I don't think this issue has been resolved.  
I will defer to the group (and perhaps we can discuss this on Wednesday) as 
to whether we should continue our course of action and use the Singapore 
entity to apply for the SBO license while we continue to discuss the overall 
strategy.  Thank you, Michelle



	David Merrill@ENRON_DEVELOPMENT
	11/11/00 02:34 AM
		 
		 To: Robbi Rossi@EES
		 cc: Michelle Hicks@Enron Communications, Wayne Gardner/Enron 
Communications@Enron Communications, <donald_lassere@enron.net>, 
Robin_Hill@enron.net @ ENRON COMMUNICATIONS, <jan_haizman@enron.net>
		 Subject: Company Name to Use for our Singapore License

Robbi, Michelle:   This is to get guidance on whether I can use our newly 
established
Singapore Company (below) in the application for our Singapore SBO license.
The license form requires me to name our company;  its Singapore Business 
Registration
Number; its principal activities as registered in the registry of companies; 
its address, 
its corporate structure, its financial information, a contact person 
name/designation,
a contact number, etc.

So normally I would reason to use this new company for this application.  Yet 
in one of our
conference calls someone said (if I understood) that this company was only 
for holding
title to equipment, not for all of the bandwidth trading, capacity providing 
and content
activities described in the company purposes.   I suppose this distinction is 
for a tax 
purpose.  

Be that as it may, I am faced with this form.   Can I use this company 
(below)  in the application?   
If not, then what company, and what are all of its characteristics as listed 
in para one above??

To think ahead a bit, we will also need a company name for our Pioneer Tax 
status application.
For sure that will have to be a Singapore Based company since the whole 
rationale for Pioneer
Status revolves around locating in Singapore.   So maybe we should be using 
the same name
for both applications?  

Further, if we did get Pioneer Tax status (most favorable rate is zero tax 
for five years
though we may or may not get that), wouldn't all of our standard tax 
avoidance strategies 
need to be re-looked at in the light that they possibly may not be as needed 
in this case?

Please provide me guidance.   Many thanks.     PS:  I will be in Houston the 
week of Nov 28
if needed for discussions but earlier guidance appreciated. 

David
 

---------------------- Forwarded by David Merrill/ENRON_DEVELOPMENT on 
11/11/2000 04:05 PM ---------------------------


"Ang & Partners" <mail@angpartners.com> on 11/10/2000 04:24:36 AM
Please respond to "Ang & Partners" <mail@angpartners.com>
To: <David.Merrill@enron.com>
cc:  

Subject: Enron Broadband Services Singapore Pte Ltd (the "Company")


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?
Dear Mr Merrill
?
I refer to our telephone conversation this  afternoon and as requested, I 
attach herewith a copy of the Certificate of  Incorportion of the Company and 
the main object clauses of the Company, for your  attention.
?
?
Regards
?
Preetha Pillai
ANG &  PARTNERS
?
Encls
 - Objects-MA.pdf
 - Certificate.pdf