- 41 - (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 changePage: Previous 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 Next
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