- 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 paid            
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