Amoco Corporation (Formerly Standard Oil Company (Indiana) and Affiliated Corporations - Page 34

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          the Egyptian Government, as compensation for no longer taking tax           
          credits for Amoco Egypt's taxes.                                            
               In January 1981, Amoco submitted another ruling request to             
          the IRS seeking a determination that taxes paid by EGPC on Amoco            
          Egypt's behalf under the existing agreements were creditable.               
          Amoco believed that the basic provision whereby Amoco Egypt's               
          taxes were paid by EGPC would pass muster under the temporary               
          regulations and, if so, that it would not be necessary to                   
          continue the difficult negotiations on the PPIA approach. In                
          stating the reasons why the Egyptian tax system met the                     
          requirements for a creditable tax under section 903, Amoco                  
          stated: "No portion of Amoco's tax is refunded to it, nor is any            
          portion of such tax used directly or indirectly to provide a                
          subsidy to Amoco."  The computation of EGPC's taxes was not                 
          addressed, and Amoco did not indicate that EGPC had claimed a tax           
          credit for taxes paid on behalf of Amoco Egypt.                             
               In February 1981, EGPC formed a new negotiating team that              
          included Mansour.  Mansour was more amenable than the previous              
          lead negotiator, Kaptan, to handling the loss of EGPC's right to            
          the credit under Article IV(f)(6) through a reduction in the                
          royalty rate.                                                               
               In March 1981, Amoco Egypt sent a letter to EGPC to resolve            
          an impasse over a "keep-whole" clause.  The clause was requested            
          by EGPC as a means of recovering from Amoco Egypt the difference,           






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