Riggs National Corporation & Subsidiaries (f.k.a. Riggs National Bank and Subsidiaries) - Page 36

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               Until about the signing of the phase II restructuring                  
          agreements in January 1984, Citibank continued to press the                 
          Brazilians to reach a favorable resolution of the withholding               
          issue.  Top employees of Citibank-Brazil utilized virtually every           
          opportunity available to them, outside of the BAC's meetings, to            
          lobby Brazilian Government officials and Central Bank officials on          
          the withholding issue.16    Other  foreign  lenders,  including             
          Commercial Credit Corporation, also pressed the Brazilians to               
          resolve the withholding issue favorably to these foreign lenders.           
               On December 8, 1983, Citibank's in-house tax counsel met with          
          the general counsel of the Central Bank and presented Citibank's            
          position on the withholding issue.  During the meeting, the Central         
          Bank's general counsel indicated that DARF's would be issued by the         
          Central Bank on its restructuring debt interest remittances but             
          refused to address whether the Central Bank would issue DARF's on           
          its 432 loan program net loan interest remittances.17                       
               On January 22, 1984, the Brazilian Planning Minister, the              
          Central Bank's general counsel, and other Brazilian officials met           

          16        Job Maats, who functioned as Citibank-Brazil's                    
          financial controller, served on the BAC's withholding issue                 
          subcommittee and played a central role in Citibank's efforts to             
          obtain DARF's from the Central Bank, testified that Brazilian               
          officials were told that a favorable resolution of the                      
          withholding issue would also benefit Brazil and be in Brazil's              
          interest, because it would improve the climate to conclude a                
          restructuring deal.                                                         
          17        Citibank estimated that, for 1979 through 1983, a                 
          potential foreign tax credit of $30 million could be claimed by             
          Citibank with respect to the Central Bank's 432 program net loan            
          interest remittances.                                                       



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