Riggs National Corporation & Subsidiaries (f.k.a. Riggs National Bank and Subsidiaries) - Page 52

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          interest remittances.  We are unable to ascertain what, if any,             
          entries were made to determine:  (1) Whether the Central Bank was           
          reimbursed by the National Treasury for its withholding tax                 
          payments; or (2) whether the Central Bank received the pecuniary            
          benefit based on those withholding tax payments.  The Central               
          Bank's ruling request raised these two matters, and the March 1984          
          Brazilian IRS ruling discussed the two possibilities.21                     
               Beginning in 1984, the Central Bank issued DARF's to the agent         
          banks of the foreign lenders to whom it transmitted loan payments           
          under the DFA's and CGA's, reflecting its withholding tax payments          
          on restructuring debt interest remittances during the relending             
          periods of the DFA's and CGA's.  From 1984 through 1988 the Central         
          Bank issued a total of 324 DARF's to these agent banks.                     
          T.  Foreign Tax Credit Claimed by Petitioner in Dispute Between The         
          Parties                                                                     
               On its 1980 through 1986 income tax returns, petitioner                
          generally reported its interest income and withholding tax payments         
          with respect to its Brazilian loans on a cash basis.  Petitioner            
          claimed a foreign tax credit and reported interest income gross-up          
          when it received a DARF.  On its returns covering the period from           
          1980 through June 28, 1985, petitioner reduced the amount of                

          21        An expert witness for petitioner acknowledged that the            
          Central Bank might be entitled to reimbursement from the National           
          Treasury for its restructuring debt withholding tax payments, as            
          the Central Bank was acting on the Brazilian Government's behalf            
          and in the national interest.  However, he claimed that the                 
          Central Bank would have to ask the Brazilian Government for                 
          reimbursement and that any such expenditure would require the               
          Brazilian Congress' approval.                                               



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