Exxon Corporation - Page 24




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          apply.  See sec. 1.901-2(a)(3)(i), Income Tax Regs.  More                   
          specifically, the regulations provide that foreign taxes will be            
          treated as income taxes if and only if the taxes, judged on the             
          basis of their predominant character, satisfy each of the                   
          realization, gross receipts, and net income requirements of                 
          section 1.901-2(b), Income Tax Regs.                                        
               Generally, under section 1.901-2(b)(4)(i), Income Tax Regs.,           
          foreign taxes will be regarded as satisfying the net income                 
          requirement if, measured by their predominant character, they               
          permit recovery of the significant costs and expenses relating to           
          the income or if they provide other allowances that effectively             
          compensate for nonrecovery of such costs and expenses.7                     

          7    Pertinent language of sec. 1.901-2(b)(4)(i), Income Tax                
          Regs., is as follows:                                                       
                    (4) Net Income–(i) In general.  A foreign tax                     
               satisfies the net income requirement if, judged on the                 
               basis of its predominant character, the base of the tax                
               is computed by reducing gross receipts * * * to                        
               permit–-                                                               
                         (A) Recovery of the significant costs and                    
               expenses (including significant capital expenditures)                  
               attributable, under reasonable principles, to such                     
               gross receipts; or                                                     
                         (B) Recovery of such significant costs and                   
               expenses computed under a method that is likely to                     
               produce an amount that approximates, or is greater                     
               than, recovery of such significant costs and expenses.                 
               *  *  *                                                                
               A foreign tax law that does not permit recovery of one                 
               or more significant costs or expenses, but that                        
                                                             (continued...)           





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