Amoco Corporation (Formerly Standard Oil Company (Indiana) and Affiliated Corporations - Page 55

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          behalf of Amoco Egypt.  Article III(g)(6) of the agreement                  
          provides:                                                                   
               6.   In calculating its A.R.E. income taxes, EGPC shall                
                    be entitled to deduct all royalties paid by EGPC                  
                    to the Government and [Amoco Egypt's] Egyptian                    
                    income taxes paid by EGPC on [Amoco Egypt's]                      
                    behalf.                                                           
               The Arabic version of the above provision does not include             
          the word "minha" as did the MCA at issue herein.  The word                  
          "minha" was not used at Amoco Egypt's request.                              
               In a 1994 production sharing agreement entered into between            
          EGPC and Mobil, the English text includes a provision comparable            
          to Article IV(f)(6) herein, with the proviso, "but EGPC shall not           
          credit directly or indirectly CONTRACTOR'S Egyptian income taxes            
          against EGPC's Egyptian income taxes."                                      
          Notice of Deficiency                                                        
               In calculating allowable foreign tax credits for the taxable           
          years 1979, 1980, 1981, and 1982, petitioner included Egyptian              
          income taxes paid on behalf of Amoco Egypt by EGPC, pursuant to             
          the MCA and other concession agreements between Amoco Egypt,                
          EGPC, and the ARE, in the following amounts:                                
                    Year                   Amount                                     
                    1979                $304,015,893                                  
                    1980                498,086,280                                   
                    1981                557,873,428                                   
                    1982                453,586,679                                   
          Amoco also included these amounts in its U.S. gross income.  On             
          October 12, 1984, Amoco timely filed amended consolidated                   





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