Amoco Corporation (Formerly Standard Oil Company (Indiana) and Affiliated Corporations - Page 59

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               In calculating its A.R.E. income taxes, EGPC shall be                  
               entitled to deduct all royalties paid by EGPC to the                   
               GOVERNMENT and Amoco's Egyptian Income Taxes paid by                   
               EGPC on Amoco [Egypt]'s behalf.                                        
          The Arabic version of Article IV(f)(6) is the same except for the           
          addition of the Arabic equivalent of "therefrom" after the phrase           
          "to deduct".                                                                
               During the years at issue, EGPC interpreted Article IV(f)(6)           
          as authorizing it to credit the Egyptian income taxes of Amoco              
          Egypt against its Egyptian income taxes rather than to deduct               
          such taxes in calculating its income.                                       
               The determination of petitioner's entitlement to a foreign             
          tax credit under section 901 depends upon the resolution of the             
          following issues:                                                           
               (1)  Whether Article IV(f)(6) authorizes EGPC to take a                
          credit for Amoco Egypt's Egyptian income taxes paid by EGPC.                
          Analysis of this issue involves consideration of whether the MCA            
          is a contract or a law of the ARE, including consideration of the           
          impact of the variation between the English and Arabic versions             
          of Article IV(f)(6), and, in either case, consideration of the              
          intent of the parties and the extent to which such intent should            
          be taken into account.                                                      
               (2)  The impact of the position of the Egyptian Tax                    
          Department over the years in respect of the taking of the credit            
          by EGPC, and particularly its action in 1992, disapproving such             







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