- 55 - 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 consolidatedPage: Previous 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 Next
Last modified: May 25, 2011