Amoco Corporation (Formerly Standard Oil Company (Indiana) and Affiliated Corporations - Page 71

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          tax credit purposes whether EGPC took a credit.  Respondent's               
          assertion of ratification confuses knowledge (which Amoco and               
          Amoco Egypt had) with approval (which they did not give).                   
               Respondent emphasizes that, in Amoco's ruling requests,                
          Amoco never stated that EGPC was claiming a credit for taxes paid           
          on Amoco Egypt's behalf.  We are not persuaded that, given its              
          view as to the governmental status of EGPC, Amoco was obligated             
          to detail the factual basis for its assertion that no subsidy was           
          involved, see infra p. 91.  In any event, any failure on the part           
          of Amoco to discharge any such obligation would simply be with              
          respect to Amoco's ability to rely on those rulings.  Neither the           
          rulings nor the facts on which they were premised are relevant to           
          our determination.                                                          
               Of greater significance than the foregoing analysis of the             
          meaning of Article IV(f)(6) and the relevant Egyptian tax law is            
          the ruling of the ETD to which we now turn our attention.                   
               From 1975 to 1992, EGPC claimed a credit each year against             
          its income taxes for Amoco Egypt's income taxes, and its actions            
          were not challenged by the ETD for the taxable years through June           
          30, 1980.  In 1992, after reviewing the MCA, the ETD determined             
          that EGPC was not entitled to such credit.  EGPC, at the urging,            
          and with the approval, of the Minister of Petroleum, acquiesced             
          in the ETD determination and agreed to pay back taxes, calculated           
          on the basis of a deduction of Amoco Egypt's taxes.                         






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