- 32 - The phase I DFA and the phase II DFA did not cover foreign debt payments that were due after January 1, 1985. During the phase III negotiations, Brazil and its foreign lenders agreed to about six interim loan arrangements under which debt payments due after January 1, 1985, being made by Brazilian borrowers would be held by the Central Bank as "interim deposits". These interim arrangements required the Central Bank to pay the foreign lenders interest on such interim deposits, on a "net quoted" basis. The interim arrangements themselves did not provide for any relending period, as the Brazilians and the BAC envisioned that these interim deposits would ultimately be rolled over into and covered under the phase III DFA they anticipated would be concluded. P. Various Foreign Lenders' Efforts During the Phase I and Phase II Restructuring Negotiations To Have the Central Bank Issue Them DARF's With Respect to Its Net Loan Interest Remittances For certain U.S. and other foreign lenders who were in a position to claim and utilize them, foreign tax credits potentially represented a significant further source of tax benefits, with respect to their Brazilian loans. Although, in the case of a net loan, the U.S. lender would have to pay U.S. income tax with respect to the additional interest income resulting from the gross- up, a foreign tax credit equal in amount to the additional interest income could be utilized to reduce the lender's U.S. income tax liability on a dollar-for-dollar basis.11 11 See Nissho Iwai Am. Corp. v. Commissioner, 89 T.C. 765, 772-773 (1987).Page: Previous 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 Next
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