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On September 18, 1979, Amoco sent a copy of the September 5,
1979, ruling request to EGPC. In February 1980, Amoco requested
expeditious treatment of the ruling. Amoco's chairman wrote the
U.S. Secretary of Commerce and the U.S. Secretary of the
Treasury, with respect to the ruling request. On August 5, 1980,
Amoco's chairman met with the Secretary and Assistant Secretary
of the Treasury to discuss the request and was advised that a
favorable ruling would be issued shortly.
In July 1980, Amoco filed a supplementary request, asking
for a favorable ruling on the existing MCA, i.e., without the
proposed amendments as set forth in the September 5, 1979,
request; or, anticipating a negative ruling, for such negative
ruling to be applied prospectively for years beginning after the
issuance of a favorable ruling on the PPIA approach. The
supplemental request did not address the computation of EGPC's
taxes.
On August 7, 1980, the IRS issued a favorable ruling on
Amoco's September 5, 1979, request. A ruling on the supplemental
request was issued on August 11, 1981, which did not address the
indirect subsidy rules under section 4.901-2(f), Temporary Income
Tax Regs, 45 Fed. Reg. 75647, 75653 (Nov. 17, 1980), see infra p.
34.
Amoco was aware that the "lack of a creditable Egyptian
income tax could result in reduced corporate earnings on the
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