- 36 - 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.Page: Previous 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 Next
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