Riggs National Corporation & Subsidiaries (f.k.a. Riggs National Bank and Subsidiaries) - Page 79

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          36(...continued)                                                            
               of--were the state of Parana the recipient of the                      
               interest on which the union would claim a tax, I would                 
               recognize the immunity.  However, we are in a different                
               situation in this case in which the recipient of the                   
               interest is a third party, and in this case the                        
               immunity does not apply.                                               
                    Q.  I wasn't particularly talking about the                       
               *  *  *  [Parana I--1st Panel and Parana I--Full                       
               Bench decisions]; I was talking about some of the other                
               cases we discussed.                                                    
                    A.  Oh, the other, the two, I would say they                      
               should be approached with two qualifications.  The                     
               first one is that they all concern, except for one,                    
               Resolution 63 loans, which is a different thing.  And                  
               most important in that, none of these loans which were                 
               dealt with in these other cases were import financing;                 
               they were all, the three or the five of them, if you                   
               compute all of them, straightforward currency loans.                   
               And as we were discussing yesterday, the Decree Law                    
               401, which the court applied or argued in all these                    
               cases, only * * * [applies] to import financing and not                
               to currency loans.                                                     
                    That's the two main reservations or qualifications                
               that apply to these precedents of the Supreme Court.                   
                    Q.  So you acknowledge that the Supreme Court                     
               cases we discussed yesterday did not involve import                    
               financing, correct?                                                    
                    A.  Yes.  In the--my--the main criticism they may                 
               be subject to is that although they do not involve                     
               import financing, they apply one legal provision which                 
               applies only to import financing.  That's the big                      
               contradiction of these decisions, and that's their weak                
               point.                                                                 
                    Q.  That's the reason you think the decisions are                 
               wrong or you [are in] disagreement with them, right?                   
                    A.  Well, I disagree with them, yes.  Sure.                       
                    Q.  Okay.                                                         
                                                             (continued...)           



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