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For purposes of clarification, the following are
public-sector entities:
-the Union, States, Federal District, and
Municipalities * * * ;
-federal territories * * * ;
-federal, state, and municipal autonomous government
agencies * * * .
Consequently, we recommend that, in the case of
transactions with the characteristics outlined above, the
corresponding Certificates be issued with the additional
observation:
"Payment/collection of withholding tax on income
is waived on remittance(s) (indicate the nature of
the remittance) covered by this Certificate
(Official Letter SRF no. 368, dated 6/10/80)."
M. Latin Debt Crisis
A number of Latin American countries, including Brazil and
Mexico, incurred large foreign debts. Beginning in about the early
1980's, some of these countries experienced problems in paying
their foreign debts. This Latin debt crisis persisted for a number
of years.
In about 1982, a large number of Mexico's foreign lenders
(including some major international banks in the G-7 countries) and
the Mexican Government agreed to a restructuring of Mexico's
foreign debt.
Brazil began experiencing similar problems in paying its
foreign debt in 1982. In late 1982, the Brazilian Government
declared a moratorium with respect to the repayment of Brazil's
foreign debt.
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