Riggs National Corporation & Subsidiaries (f.k.a. Riggs National Bank and Subsidiaries) - Page 19

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                    For purpose of this article, the remittance to a                  
               foreign country is considered the generative fact of tax,              
               and the remitter is considered the contribuente.                       
          L.  SRF 368 and FIRCE 80                                                    
               On June 10, 1980, Secretary Francisco Dornelles (Dornelles),           
          the head of the Brazilian equivalent of the Internal Revenue                
          Service (Brazilian IRS), issued SRF 368 to the head of the Central          
          Bank's Department of Foreign Capital Fiscalization and Registration         
          (FIRCE).  SRF 368 was an "officio", a formal written communication          
          between two governmental agencies that is binding upon the                  
          governmental agencies.  SRF 368 stated, in pertinent part:                  
               Subject:  Notification of waiver of payment of income                  
                         tax on remittances abroad                                    
                    Ref. Off. Let. FIRCE-1-0-80/059, dated 6/3/80                     
                    Dear Sir:                                                         
                    In reply to the above mentioned official letter, of               
               interest to your Department, I hereby inform you, for                  
               such measures as you may deem necessary, that, in the                  
               exercise of the powers  delegated  to  me  by  MF                      
               Administrative Ruling 648/79, I AUTHORIZE the waiver of                
               payment of withholding income tax incident on the                      
               remittance of interest and other legal charges on behalf               
               of Banco do Brasil S/A-Grand Cayman Branch with respect                
               to the foreign loan transaction in the amount of $60                   
               million contracted by the Federative Republic of Brazil,               
               Ministry of Foreign Relations at that bank.                            
               *       *       *       *       *       *       *                      
               2.   I would also like to take this opportunity to inform              
               you of the directive contained in SRF Official Letter no.              
               1016 dated 12/26/79 addressed to DECAM (Departmento de                 
               Cambio) [Department of Foreign Exchange], according to                 
               which the Central Bank of Brazil, independently of any                 
               prior statements made by this Secratariat, is authorized               






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