Riggs National Corporation & Subsidiaries (f.k.a. Riggs National Bank and Subsidiaries) - Page 4

                                        - 4 -                                         
          Commissioner, T.C. Memo. 1992-282, affd. 69 F.3d 1404 (8th Cir.             
          1995); First Chicago Corp. v. Commissioner, T.C. Memo. 1991-44;             
          Continental Ill. Corp. v. Commissioner, T.C. Memo. 1988-318, affd.          
          without published opinion sub nom. Citizens & S. Corp. & Subs. v.           
          Commissioner, 919 F.2d 1492 (11th Cir. 1990), affd. in part and             
          revd. in part 998 F.2d 513 (7th Cir. 1993) and Nissho Iwai Am.              
          Corp. v. Commissioner, 89 T.C. 765 (1987).  However, none of those          
          cases involved withholding tax paid by a tax-immune Brazilian               
          governmental entity/borrower, like the Central Bank here, on its            
          Brazilian restructuring debt interest remittances.                          
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are found                   
          accordingly.  The parties have further stipulated in evidence               
          portions of the trial transcripts in the Continental Illinois and           
          Nissho Iwai cases and various exhibits related to the testimony of          
          certain witnesses in those cases.                                           
          A.  Background                                                              
               Petitioner's principal place of business was in Washington,            
          D.C., at the time the petition was filed.                                   
               Riggs National Corporation is the parent company of a group of         
          corporations which filed consolidated income tax returns for the            
          years in issue.  Its wholly owned subsidiary Riggs National Bank            
          regularly made and participated in loans to borrowers located in            
          foreign countries, including Brazil.                                        






Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  Next

Last modified: May 25, 2011