Riggs National Corporation & Subsidiaries (f.k.a. Riggs National Bank and Subsidiaries) - Page 66

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          Andre I decision), holding that the municipality did not have to            
          pay withholding tax on its interest remittances as repass borrower          
          with respect to a Resolution 63 repass loan to construct a                  
          municipal supply center.  The loan involved in the Santo Andre I            
          decision was a net loan.  The reporting Brazilian Supreme Court             
          Justice noted the prior Parana I--1st Panel and Parana II                   
          decisions, but adopted and utilized the Parana II decision's                
          rationale for distinguishing the Parana I--1st Panel decision.              
          This Justice stated that the decision rendered in Santo Andre I was         
          "oriented in the same line of jurisprudence" as the Parana II               
          decision.                                                                   
               On April 13, 1993, a panel of the Brazilian Supreme Court              
          issued its ruling not to recognize the Brazilian Government's               
          appeal in Federal Union v. Municipal Prefecture of Santo Andre              
          (hereinafter for convenience referred to as the Santo Andre II              
          decision).  The loan to the municipality in Santo Andre II was a            
          Resolution 63 repass net loan.  In its appeal, the Brazilian                
          Government argued that the Parana II decision was distinguishable           
          and did not support holding the municipality to be immune from              
          payment of withholding tax, as the foreign loan in Parana II had            
          been directly made to the State of Parana.                                  
               D.  The Parties' Experts                                               
                    1. Petitioner's Experts.                                          
               Petitioner offered testimony on the applicable Brazilian law           
          concerning the Central Bank's liability for withholding tax on its          




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