Riggs National Corporation & Subsidiaries (f.k.a. Riggs National Bank and Subsidiaries) - Page 42

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          during the relending periods of the DFA's and CGA's because until           
          the expiration of the applicable relending period the loan funds            
          were not yet irrevocably committed to the Central Bank, and it,             
          therefore, had to pay withholding tax on behalf of future,                  
          unidentified "borrowers-to-be" (the borrowers-to-be theory).  They          
          incorporated this borrowers-to-be theory into the revised draft             
          ruling they prepared, which revised draft ultimately became the             
          final version of the ruling the Brazilian IRS issued to the Central         
          Bank in March 1984.                                                         
               By letter dated March 14, 1984, the Brazilian Finance Minister         
          forwarded to the Central Bank's President the Finance Minister's            
          decision on the ruling request and the ruling the Brazilian IRS had         
          issued.  The March 14, 1984, letter stated, in pertinent part:              
               I refer to the inquiry made by your Bank regarding the                 
               tax treatment for the Agreements called  *  *  *  [CGA                 
               and DFA].                                                              
               2.  In this respect, I enclose a copy of the opinion of                
               *  *  *  [the Brazilian IRS] on the matter, as well as of              
               the decision I issued on this date on account of the                   
               discussions I had jointly with you for the negotiation of              
               such agreement.                                                        
          The ruling issued to the Central Bank was a private ruling that was         
          given limited circulation.  The ruling was not made available to            
          the public and was not published in the Brazilian Government's              
          Official Gazette.                                                           
               The Finance Minister's decision stated:                                
               Case No.:                                                              
               Interested Party:  CENTRAL BANK OF BRAZIL                              





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