Jeff:  I'll call you later.  Sara

Sara Shackleton
Enron North America Corp.
1400 Smith Street, EB 3801a
Houston, Texas  77002
713-853-5620 (phone)
713-646-3490 (fax)
sara.shackleton@enron.com
----- Forwarded by Sara Shackleton/HOU/ECT on 01/18/2001 09:33 AM -----

	Peter Russell@ENRON
	01/17/2001 09:14 AM
		
		 To: Sara Shackleton/HOU/ECT@ECT
		 cc: 
		 Subject: Re: "ECT Europe Accounting" as ENA hedge counterparty

Sara

I am not sure I understand the question.  What do you mean by RMT?  

Here is an explanation of what happened here in London:

Due to cash flows originated by tax in London before year end,  some Enron 
Europe companies had FX positions that needed to be hedged.  However, due to 
tax reasons we could not hedge the FX positions in the entities in which they 
arose because the hedge gains or losses would be subject to the 'sub-part F' 
income rules (and liable to double tax).  

Tax therefore suggested that we transact the hedges in the name of 'ECT 
Europe Accounting Entity' (company 912), where they would be consolidated 
into Enron Europe for management accounting but would be within a US legal 
entity and therefore not subject to double tax.  My understanding is that 912 
is a branch of ENA and therefore there is a hedge transacted between ENA 912 
and ENA.

We have been trying to identify the hedges within company 912 but cannot see 
them there.  Can you help with this?

Regards

Peter


From: Sara Shackleton@ECT on 17/01/2001 09:00 CST
To: Jeff Blumenthal/HOU/ECT@ECT, Peter Russell/EU/Enron@Enron
cc: Laurel Adams/HOU/ECT@ECT 

Subject: "ECT Europe Accounting" as ENA hedge counterparty

Jeff and Peter:

Has this question been resolved?  Please let me hear from you.  We need to 
make certain that these transactions are properly booked.  Thanks.  Sara

Sara Shackleton
Enron North America Corp.
1400 Smith Street, EB 3801a
Houston, Texas  77002
713-853-5620 (phone)
713-646-3490 (fax)
sara.shackleton@enron.com
----- Forwarded by Sara Shackleton/HOU/ECT on 01/17/2001 08:58 AM -----

	Sara Shackleton
	01/10/2001 09:50 AM
		 
		 To: Jeff Blumenthal/HOU/ECT@ECT
		 cc: 
		 Subject: "ECT Europe Accounting" as ENA hedge counterparty

Jeff:  Do you have an answer yet?  Sara

Sara Shackleton
Enron North America Corp.
1400 Smith Street, EB 3801a
Houston, Texas  77002
713-853-5620 (phone)
713-646-3490 (fax)
sara.shackleton@enron.com
----- Forwarded by Sara Shackleton/HOU/ECT on 01/10/2001 09:49 AM -----

	Sara Shackleton
	01/03/2001 01:08 PM
		 
		 To: Jeff Blumenthal/HOU/ECT
		 cc: 
		 Subject: "ECT Europe Accounting" as ENA hedge counterparty

Jeff:

In connection with the instructions given by London to Shane Dallmann, note 
that the instruction for ENA to transact the Euro hedges was given by Peter 
Russell.  Please advise as to whether these should be RMT transactions and 
which Enron affiliate should be involved.  Thanks.   Sara