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was the March 1984 private ruling that the Brazilian IRS ultimately
issued to the Central Bank, which ruling is more fully discussed
below.
Notes of the January 22, 1984, meeting taken by the lead
attorney of the law firm that served as the BAC's counsel,
stated:
Rhodes
(1) Banks think 83 will be solved.
(2) IRS won't accept 84 if don't get 83.
(3) negative feeling for banks in the future.
Sobreira [Central Bank's general counsel]
(1) Tax owed by anyone paying interest or fees
abroad.
(2) Authority that remits charged with deduction
& paying.
(3) Cent Bk agrees to pay on acct of Banks.
(4) Only way CB can pay is if law is interpreted
to require payment. Interpretation is from
Treasury which has issued the interpretation.
(5) Treasury legal opinion applies to 1984 but
not to 1983.
Waiting for XXXXXX
(1) Delfim [the Brazilian Planning
Minister] says decree will be solved by
inserting limit.
(2) Wh tax. Phase I and phase II from 1/1/84 on
during reborrowing period.
� Agreement of Delfim.
Rhodes + Coleman [the Morgan Bank senior
executive who functioned as the BAC's deputy
chairman] accept #1.
Rhodes says he can't guarantee Bank acceptance of
#2.
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