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          Bank in June 1980, and was consistent with certain prior decisions          
          of the Brazilian Supreme Court that are discussed more fully                
          hereafter.  Pursuant to SRF 368, the Central Bank (which in Brazil          
          serves an instrumental role in ensuring that the withholding tax            
          due on interest remittances abroad is collected), following its             
          issuance of FIRCE 80 in May 1981, did not require withholding tax           
          to be collected from and paid by public-sector entities, like               
          itself, on their net loan interest remittances abroad.  Beginning           
          in 1984, the Central Bank purportedly paid withholding tax on its           
          restructuring debt interest remittances during the relending                
          periods of the DFA's and the CGA's, pursuant to the borrowers-to-be         
          theory applied in the March 1984 Brazilian IRS private ruling               
          issued to the Central Bank.                                                 
               C.  Brazilian Supreme Court Decisions                                  
               The following Brazilian Supreme Court decisions are apposite           
          in understanding the respective arguments of the parties and their          
          experts concerning the Central Bank's liability for the payment of          
          withholding tax on its net loan interest remittances to foreign             
          lenders.                                                                    
               On September 24, 1974, a panel of the Brazilian Supreme Court          
          issued its unanimous decision in Federal Govt. v. Highway Dept. of          
          the State of Parana (hereinafter referred to for convenience as the         
          Parana I--1st Panel decision), reversing the decision of the lower          
          Brazilian Federal Court of Appeals and holding that the State of            
          Parana was required to pay withholding tax on its remittance of             
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