- 48 - problem of creditability for petroleum investment in Egypt; and (5) that EGPC's practice could be corrected at no cost to the Egyptian Government. A May 7, 1992, draft adds that ETD's audit position that EGPC should take a deduction, as reflected in the May 2, 1992, letter, provides an additional setting for resolving the matter. Lenahan's pre-meeting notes show that he planned to tell Banbi that EGPC's agreement to the ETD audit position would provide an administrative solution to the tax credit problem. Amoco, represented by Pitman, Chiati, and Lenahan, met with Minister of Petroleum Banbi on May 13, 1992, where they raised all of the main talking points, including ETD's audit dispute with EGPC. Amoco told Banbi that it would be potentially harmful to Amoco in its dispute with respondent if EGPC vigorously contested the issue and wrote position papers and appealed the issue, and Banbi indicated that would not happen. Banbi indicated that he (1) was aware of the ETD determination, (2) had already concluded that EGPC would comply with that determination, (3) already had instructed an EGPC official to quantify the effect of correcting EGPC's prior credit practice, and (4) was prepared to do what was right. Banbi further indicated his preference to find an administrative solution such as that offered by the ETD audit. Banbi also indicated his awareness that the U.S. creditability problem applied to all U.S. companies and that he wanted to remove the cloud of uncertainty regarding foreign tax creditability. Banbi told Amoco to advise other U.S.Page: Previous 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 Next
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