Amoco Corporation (Formerly Standard Oil Company (Indiana) and Affiliated Corporations - Page 1

                                 T.C. Memo. 1996-159                                  

                               UNITED STATES TAX COURT                                

             AMOCO CORPORATION (Formerly STANDARD OIL COMPANY (INDIANA))              
                     AND AFFILIATED CORPORATIONS, Petitioner v.                       
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 20471-92.                   Filed March 28, 1996.           

                    S, a subsidiary of P, entered into a concession                   
               agreement with E, an entity owned and controlled by the                
               Egyptian Government.  Under the agreement, which had                   
               the force of law, E was responsible for the payment of                 
               S's Egyptian income tax liability.  For the years in                   
               issue, E took a credit against its own tax liability                   
               for the amount of taxes paid on behalf of S.  The                      
               Egyptian Tax Department determined that E was not                      
               entitled to a credit and was allowed only to deduct                    
               such payments from its taxable income.  It assessed                    
               back taxes against E for a portion of the years in                     
               issue.  Collection was foreclosed by the running of the                
               Egyptian statutory period of limitations.  Held, E was                 
               not authorized to credit Egyptian taxes paid on behalf                 
               of S against its income tax liability.  Held, further,                 
               there was no refund of Egyptian taxes to or for the                    
               account of P.  Held, further, E should be included in                  
               the term "foreign country" for purposes of sec. 901,                   

Page:   1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  Next

Last modified: May 25, 2011