Amoco Corporation (Formerly Standard Oil Company (Indiana) and Affiliated Corporations - Page 60

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          credit.  Implicated in this issue is the application of the "act            
          of state" doctrine.                                                         
               (3)  Whether the taking of the credit by EGPC for Amoco                
          Egypt's taxes should be treated as a tax exemption, refund, or              
          subsidy so as to require the conclusion that the Egyptian income            
          taxes were not paid within the meaning of section 901.  Analysis            
          of this issue involves, among other considerations, the question            
          whether EGPC, whose surplus was paid annually to the ARE, should            
          be treated as an integral part of, or a separate entity from, the           
          Government of the ARE and, in this context, whether the                     
          characterization of a subsidy can apply where the funds involved            
          are, at all times, funds of the ARE.                                        
               (4)  Depending on our resolution of the foregoing issues,              
          the impact on petitioner's foreign tax credits of the difference            
          in exchange rates between the time of the payments by EGPC during           
          the years in issue and its payment of its back taxes after the              
          disallowance in 1992 of the credits it took for Amoco Egypt's               
          taxes.                                                                      
               One additional comment is necessary before turning to a                
          detailed consideration of the above-described issues.  Throughout           
          these proceedings, respondent has sought to capitalize on the               
          alleged variations over the years in petitioner's and its                   
          counsel's approach to the situation involved herein and on the              
          activities of representatives or officers of petitioner and Amoco           
          Egypt, including their counsel.  Respondent has expressly                   




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