Amoco Corporation (Formerly Standard Oil Company (Indiana) and Affiliated Corporations - Page 41

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                         (1) the amount of such tax is used (directly                 
                    or indirectly) by the country imposing such tax to                
                    provide a subsidy by any means to the taxpayer, a                 
                    related person (within the meaning of section                     
                    482), or any party to the transaction or to a                     
                    related transaction, and                                          
                         (2) such subsidy is determined (directly or                  
                    indirectly) by reference to the amount of such                    
                    tax, or the base used to compute the amount of                    
                    such tax.                                                         
               From 1988 to 1990, Amoco engaged in repeated attempts to               
          obtain a technical correction of section 901(i).                            
               Also from 1988 to 1990, Amoco, with help from EGPC, the                
          Petroleum Ministry, and the U.S. Ambassador to the ARE,                     
          endeavored to persuade the U.S. Treasury Department and the                 
          Congress regarding the status of EGPC as a part of the Egyptian             
          Government and the nonapplication of the indirect subsidy rules             
          to entities like EGPC.                                                      
          Egyptian Resolution of Credit Issue                                         
               On March 20, 1991, Jim Lenahan, assistant general tax                  
          counsel of Amoco, consulted Nordberg on whether Amoco should ask            
          the Egyptian Government "to remedy the Egyptian deal either                 
          prospectively or retroactively."                                            
               On December 24, 1991, Miller & Chevalier, petitioner's                 
          counsel in this case, outlined a "program" for obtaining                    
          assistance from the Egyptian Government.  The program proposed              
          meetings between senior Amoco personnel and senior Egyptian                 
          officials, as well as lower-level meetings.  The program                    
          contemplated convincing EGPC and the Petroleum Ministry to change           




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