- 154 -                                                   
            tion.112  Accordingly, we sustain respondent's determinations that                             
            (1) for the period that commenced on November 12, 1985, the date                               
            on which BB Loan No. 3 was funded, and ended on September 12,                                  
            1986, the date on which that loan was repaid, Radcliffe was                                    
            required to withhold tax on the full amount of the interest that                               
            it, in form, paid to Bangkok Bank LA branch on BB Loan No. 3 and                               
            (2) petitioner, as transferee of Radcliffe, is liable for that                                 
            withholding tax liability of Radcliffe.                                                        
                         4.    UB $570,000 Pre-March 1984 Loan and                                         
                               UB $570,000 Renewed Loan Transactions                                       
                  The record establishes that, in form, Union Bank funded a                                
            $570,000 loan to BOT and Union Bank's affiliate Standard Char-                                 
            tered Bank HK held a deposit in the name of Merit that secured                                 
            that loan.  With respect to the UB $570,000 renewed loan transac-                              
            tion, the record establishes that, in form, Union Bank renewed                                 
            its $570,000 loan to BOT and Union Bank's affiliate Standard                                   
            Chartered Bank, Singapore, held a deposit in the name of Forward                               
            that secured that loan.  The record also shows that, in form,                                  
            Union Bank received interest from BOT with respect to the UB                                   
            $570,000 pre-March 1984 and renewed loan transactions and, al-                                 
            though the record is silent on this point, its affiliate Standard                              
            Chartered Bank HK presumably paid interest to Merit on its                                     
            $570,000 deposit and its affiliate Standard Chartered Bank,                                    
            112  See first paragraph supra note 108 for our views on peti-                                 
            tioner's alternative argument about portfolio interest.                                        
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