- 32 -                                         
               In the course of discussions, one idea that was raised, but            
          quickly dismissed, was to have a law passed entitling EGPC to a             
          credit for taxes paid directly by Amoco Egypt.  Amoco left the              
          first negotiating session having agreed to look into the U.S. tax           
          consequences of allowing EGPC a tax credit for Egyptian taxes               
          paid directly by Amoco Egypt, by inserting language to such                 
          effect into the MCA.  Amoco also considered amending the language           
          of Article IV(f)(6).                                                        
               Following the September 1980 meetings in the ARE, Amoco                
          officials met with Nordberg, who reiterated to Amoco that Article           
          IV(f)(6) should be deleted from the agreement and, moreover,                
          advised that a continuation of EGPC's credit practice could                 
          jeopardize U.S. tax creditability.  Nordberg advised that                   
          allowing EGPC a tax credit would severely jeopardize a favorable            
          ruling from the IRS.  The advice was based on Nordberg's analysis           
          of Rev. Rul. 78-258, 1978-1 C.B. 239, and the proposed                      
          regulations under section 901, under which, he thought, allowing            
          EGPC a credit would constitute an indirect subsidy.  Amoco                  
          accepted Nordberg's advice.  Nordberg advised that it would not             
          jeopardize U.S. creditability if EGPC got relief in a manner not            
          related to the amount of Amoco Egypt's tax payments, including if           
          EGPC were forgiven a fixed fraction of its taxes, or EGPC's                 
          royalty obligation were eliminated.                                         
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