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credit under Article IV(f)(6). Petitioner counters with the
assertion that, properly interpreted, both the English and Arabic
versions of the MCA and the income tax law of the ARE only
entitled EGPC to claim a deduction for the income tax which Amoco
Egypt was obligated to pay.
The English version of Article IV(f)(6) of the MCA provides:
"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." Looking only at this version of Article IV(f)(6), we
think that a strong argument can be made that it provides EGPC
with a deduction of Amoco Egypt's tax from income and not a
credit against EGPC's income tax. Such an interpretation would
accord with the use of the word "deduction" in Annex E of the MCA
which provides that Amoco Egypt's taxes are to be computed on the
"gross income of AMOCO less the costs and deductions * * *".
Such an interpretation would also reflect the intention of the
parties, see infra pp. 66-70. Moreover, it would conform to the
general understanding, under the U.S. tax context, that the word
"deduct" means to subtract from gross income. See, e.g., sec.
62(a) (defining adjusted gross income as "gross income minus the
following deductions"); Black's Law Dictionary at 413 (6th ed.
1990). Before adopting this conclusion, however, we need to deal
with the Arabic version of Article IV(f)(6).
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