- 33 - In early November 1980, a second round of negotiations took place between Amoco and EGPC, where Amoco representatives communicated Nordberg's advice to EGPC, that EGPC could not be allowed to credit Amoco Egypt's taxes against its tax liability. EGPC indicated that it understood Amoco's position. However, EGPC continued to indicate the credit practice, and keeping EGPC whole, was an open issue through meetings in December 1980. At a December 18, 1980, negotiating session, EGPC indicated that it would drop the credit issue. It was understood by Amoco that EGPC would deal with the ETD as far as being kept whole, but that EGPC would not arrange with the ETD to take credits for Amoco Egypt's taxes. In November 1980, temporary regulations under section 901 were released, indicating that it would be permissible for U.S. tax creditability purposes for a foreign national oil company to pay a contractor's taxes. See sec. 4.901-2, Temporary Income Tax Regs., 45 Fed. Reg. 75647, 75648 (Nov. 17, 1980). In light of the temporary regulations, Amoco reviewed the EGPC negotiations and planned for a new IRS ruling request on the existing MCA. Part of Amoco's strategy was to protect its U.S. tax credits claimed for 1979 and 1980. In a January 1981 negotiation meeting, EGPC indicated that it was attempting to get a reduction in the royalty rate it paidPage: Previous 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 Next
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