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Such letter was prepared by Amoco Egypt's finance manager,
Richard Dudley, although it was signed by the president of Amoco
Egypt, D. B. Wilkie. On September 16, 1980, Dudley wrote the ETD
about the change of EGPC's fiscal year and stated: "Since EGPC
pays our taxes and credits such payments against their own taxes,
we must furnish EGPC with data on our accrued taxes for the
period January 1 to June 30, 1980." Dudley consequently wrote a
telex to Amoco in the United States regarding the information
requirement, stating "Amoco taxes paid by EGPC are credited
against their payment." Dudley had considerable tax-related
experience with production sharing agreements, although he had no
knowledge of the negotiation of the MCA, and was not experienced
with the preparation of Amoco Egypt's tax returns. Dudley's
statements in the above correspondence reflected his impressions,
rather than his reasoned analysis of the MCA. Dudley had no
understanding of the impact of EGPC's treatment of taxes paid on
Amoco Egypt's behalf on Amoco's U.S. tax liability.
Respondent's Knowledge as to EGPC's Credit Practice
In early February 1988, respondent was furnished with a
statement from the ETD that taxes of contractors, such as Amoco
Egypt, were taken as a credit against EGPC's tax liability.
Concurrently, respondent obtained an English translation of the
Arabic text of a provision identical to Article IV(f)(6).
In April 1988, after respondent advised Nordberg that she
had been informed of the EGPC tax credit, Nordberg went to the
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