Riggs National Corporation & Subsidiaries (f.k.a. Riggs National Bank and Subsidiaries) - Page 9

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               In contrast to a net loan, a gross loan is a loan in which             
          there is no contractual agreement between the borrower and foreign          
          lender to pay taxes imposed by the borrower's country.  With a              
          gross loan, the Brazilian borrower will deduct withholding taxes            
          that are due from the interest specified under the loan contract            
          and will pay the lender the gross interest net of taxes.                    
               From 1970 through 1986, net loans generally were the                   
          predominant type of loan extended by foreign lenders to borrowers           
          in Brazil.  With a net loan, the foreign lender shifts the risk of          
          any increase in taxes imposed by the borrower's country to the              
          borrower.  Correspondingly, in a net loan, the borrower, not the            
          foreign lender, will benefit from any reduction in or waiver of             
          taxes imposed by the borrower's country.                                    
          F.  Institution of the Subsidy/Pecuniary Benefit                            
               Under Decree-law 1,215, enacted May 4, 1972, the Brazilian             
          Minister of Finance was given discretion to grant a reimbursement           
          or reduction of, or exemption from, the withholding tax on interest         
          provided:  (1) The borrower's costs were reduced; (2) the loan was          
          of national interest, (3) the loan met the minimum repayment term           
          set by the National Monetary Council;3 and (4) the loan complied            
          with other conditions set forth by the Ministry of Finance.                 


          3         The National Monetary Council is a Government agency              
          responsible for economic programs.  Its members include the                 
          Finance Minister, the Central Bank's President, and                         
          representatives of the largest Brazilian commercial banks.  The             
          Finance Minister presides over the council's meetings.  The                 
          council acts through the Central Bank.                                      




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