- 25 - 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 thePage: Previous 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 Next
Last modified: May 25, 2011