Amoco Corporation (Formerly Standard Oil Company (Indiana) and Affiliated Corporations - Page 48

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          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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