- 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.
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