Amoco Corporation (Formerly Standard Oil Company (Indiana) and Affiliated Corporations - Page 97

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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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