Amoco Corporation (Formerly Standard Oil Company (Indiana) and Affiliated Corporations - Page 25

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          1983 MCA Amendments                                                         
               In 1976, respondent issued Rev. Rul. 76-215, 1976-1 C.B.               
          194, holding that taxes paid under an Indonesian production                 
          sharing agreement were not creditable.  On June 12, 1978,                   
          respondent issued Rev. Rul. 78-222, 1978-1 C.B. 232, holding that           
          taxes paid under a revised Indonesian production sharing                    
          agreement were creditable.                                                  
               In August 1978, in response to the Indonesian rulings, Amoco           
          decided that the MCA needed to be restructured in certain                   
          respects in order to ensure U.S. tax creditability, including               
          requiring Amoco Egypt:  (1) To pay its Egyptian income taxes                
          directly, and (2) to compute such taxes on a consolidated basis             
          rather than separately in respect of each concession.                       
               Amoco developed proposed MCA amendments to submit to the               
          U.S. Internal Revenue Service (IRS) for a favorable ruling.  The            
          provision in the MCA providing for EGPC's payment of Amoco                  
          Egypt's taxes represented a change from the generally applicable            
          Egyptian tax law pursuant to which Amoco Egypt had previously               
          paid its taxes directly and, because of the Indonesian rulings,             
          raised questions as to creditability under U.S. law.  The basic             
          approach of the proposed amendments was to provide that Amoco               
          Egypt would be subject to and pay its own taxes under the general           
          tax laws rather than have them paid by EGPC as provided in the              








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