Riggs National Corporation & Subsidiaries, f.k.a. Riggs National Bank and Subsidiaries - Page 37

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               (c)(1) of � 1.901-2A, A has established that the                       
               country X income tax as applied to dual capacity                       
               persons and the country X income tax as applied to                     
               persons other than dual capacity persons together                      
               constitute a single levy.  A has also established that                 
               that levy is an income tax within the meaning of                       
               paragraph (a)(1) of this section.  Pursuant to the                     
               terms of the contract, country X has agreed to assume                  
               any country X tax liability that A may incur with                      
               respect to A’s income from that contract.  For federal                 
               income tax purposes, A’s income from that contract                     
               includes the amount of tax liability that is imposed by                
               country X on A with respect to its income from the                     
               contract and that is assumed by country X; and for                     
               purposes of section 901 the amount of such tax                         
               liability assumed by country X is considered to be paid                
               by A.  By reason of paragraph (f)(2)(i) of this                        
               section, country X is not considered to provide a                      
               subsidy, within the meaning of paragraph (e)(3) of this                
               section, to A.                                                         
               Section 1.901-2(g)(2), Income Tax Regs., defines the term              
          “foreign country” as “any foreign state, any possession of the              
          United States, and any political subdivision of any foreign state           
          or of any possession of the United States.”                                 
               In Amoco Corp. v. Commissioner, T.C. Memo. 1996-159, an                
          affiliate of Amoco Corp. (Amoco Egypt) entered into an                      
          arrangement with the Egyptian General Petroleum Corp. (EGPC).               
          Under the agreement, EGPC assumed and paid tax Amoco owed to the            
          Egyptian Government on its income.  EGPC erroneously claimed a              
          credit against its Egyptian income taxes for the tax paid on                
          Amoco Egypt’s behalf.  The expiration of the limitations period             
          barred the Egyptian Government from recovering the tax                      
          erroneously claimed as a credit by EGPC.  The Commissioner                  
          asserted that the tax credit claimed by EGPC was an indirect                





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