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not be equated with the Egyptian Government. Given our holding
to the contrary, it follows that respondent's argument should be
and is rejected. Indeed, having concluded that EGPC was part of
the Egyptian Government, a finding of a subsidy would mean that
one can subsidize one self. In so stating, we do not imply that
respondent is necessarily precluded from treating, by regulation,
entities such as EGPC as separate from the foreign government and
therefore "another person" for purposes of determining the
existence of a subsidy.
Thus, respondent may well have salvaged its position in
respect of Example (3) by Example (4) under the section 901(i)
regulations although there is still a residual confusion because
of the presence of the two examples in different regulatory
provisions. Compare sec. 1.901-2(f)(2)(ii), Example (3), Income
Tax Regs., with sec. 1.901-2(e)(3)(iv) Example (4). See Blessing
& Pistillo, "Final Regulations on the Denial of the Foreign Tax
Credit by Reason of Certain Subsidiaries," Tax Mgmt. Intl. J. p.
78 (Feb. 14, 1992). Such confusion has been a characteristic of
the turbulent history of the foreign tax credit, particularly as
applied to oil companies such as petitioner herein. See
Isenbergh, "The Foreign Tax Credit: Royalties, Subsidies, and
Creditable Taxes," 39 Tax L. Rev. 227, 247-269 (1984); 1
Isenbergh, International Taxation 495-529 (1990).
The long and the short of the matter is that respondent
seeks to equate what might have been with what was in the taxable
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