Riggs National Corporation & Subsidiaries (f.k.a. Riggs National Bank and Subsidiaries) - Page 32

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               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).                                                             



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