Riggs National Corporation & Subsidiaries (f.k.a. Riggs National Bank and Subsidiaries) - Page 34

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          such DARF's continued until  about  the  time  the  phase  II               
          restructuring agreements between Brazil and its foreign lenders             
          were entered into in late January 1984.12                                   
               During the phase I negotiations, the Brazilians indicated that         
          they would have the Central Bank issue DARF's to the foreign                
          lenders on the Central  Bank's  restructuring  debt  interest               
          remittances on some limited basis, but they also indicated that             
          they needed additional time in which to study and arrange for the           
          implementation of the Central Bank's payment of such withholding            
          tax.13  On or about December 28, 1982, the Central Bank requested           
          a ruling from the Brazilian IRS with respect to its payment of              
          withholding tax during the relending periods of the proposed phase          
          I DFA and phase I CGA. The ruling request and the March 1984                

          12        Alexandre Leite (Leite), the head of Citibank-Brazil's            
          tax division, testified that he and Citibank had been seeking               
          DARF's from the Central Bank on 432 program net loan interest               
          remittances since at least 1979.  Leite related that the Central            
          Bank officials he met with rejected Citibank's request to have              
          the Central Bank issue such DARF's to it.  Following the Central            
          Bank's issuance of FIRCE 80 in May 1981, Leite had concluded that           
          Citibank would not be able to persuade the Central Bank to issue            
          such DARF's, as FIRCE 80 was authorized and sanctioned by SRF               
          368.                                                                        
          13        The parties disagree over whether the Central Bank was            
          legally liable for and actually paid withholding tax with respect           
          to its restructuring debt interest remittances during the                   
          relending periods of the DFA's and CGA's.  The terms "payment"              
          and "withholding tax" are used herein for convenience and are not           
          intended as ultimate findings or conclusions concerning the                 
          Central Bank's liability for and payment of such withholding tax.           
          Similarly, the use herein of terms indicating that DARF's or                
          withholding receipts were issued by the Central Bank to the                 
          foreign lenders should not be construed as our conveying any                
          legal conclusion concerning the Central Bank's liability for and            
          payment of such withholding tax.                                            



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