Exxon Corporation - Page 21




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          accelerate tax revenues relating to development of North Sea                
          petroleum resources.                                                        

                                       OPINION                                        
               With limitations not here pertinent, taxpayers may claim               
          credits under section 901 against their Federal income taxes for,           
          among other things, the amount of income and excess profits taxes           
          paid to foreign countries.  See sec. 901(b)(1).  As an exemption            
          from tax, the credit provisions of section 901 are to be strictly           
          construed.  See Inland Steel Co. v. United States, 230 Ct. Cl.              
          314, 677 F.2d 72, 79 (1982); Bank of Am. Natl. Trust & Sav.                 
          Association v. United States, 61 T.C. 752, 762 (1974), affd.                
          without published opinion 538 F.2d 334 (9th Cir. 1976).                     
               Under regulations applicable to the years in issue, foreign            
          levies are to be regarded as income or excess profits taxes if              
          they satisfy two tests:  (1) The foreign levies constitute taxes,           
          and (2) the predominant character of the taxes is that of an                
          income tax in the U.S. sense.  See sec. 1.901-2(a)(1), Income Tax           
          Regs.                                                                       
               Generally, governmental levies imposed by and paid to                  
          foreign countries are to be treated as taxes if they constitute             
          compulsory payments pursuant to the authority of the foreign                
          countries to levy taxes.  The regulations, however, also provide            
          that foreign levies will not be regarded as taxes to the extent             
          that payors of the levies receive specific economic benefits,               





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