Amoco Corporation (Formerly Standard Oil Company (Indiana) and Affiliated Corporations - Page 27

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          changes that needed to be made to the concession agreements to              
          ensure U.S. tax creditability.  Nordberg specializes in                     
          international tax matters and assisted in the restructuring of              
          the Indonesian production sharing agreement so that it resulted             
          in a creditable tax.                                                        
               Amoco developed a proposal whereby the agreements would be             
          amended to provide that Amoco Egypt would pay its Egyptian income           
          taxes directly and by deleting all of the provisions relating to            
          EGPC's payment of Amoco's Egyptian taxes on Amoco's behalf,                 
          including Article IV(f)(6) of the MCA.  Amoco also proposed the             
          use of a Petroleum Production Incentive Allowance (PPIA), which             
          was a formula under which additional oil would be allocated to              
          Amoco Egypt in order to allow it to pay its Egyptian taxes                  
          directly while keeping the net economic interests of Amoco Egypt            
          and the ARE substantially unchanged.  Amoco developed the PPIA              
          because EGPC was not willing to alter the existing production               
          split, see supra p. 20, to reflect a gross-up for the taxes to be           
          paid directly by Amoco Egypt.  EGPC found an increase in Amoco              
          Egypt's production allowance more appealing for political                   
          purposes.  Since under the PPIA approach, Article IV(f)(6) would            
          be deleted, its meaning was unimportant to Amoco at this time in            
          connection with the ruling request.                                         
               In the course of developing the proposed changes in the MCA,           
          it was understood by Amoco and its advisers that Article IV(f)(6)           






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