Norwest Corporation and Subsidiaries - Page 38

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         remit profits and capital outside Brazil at the official exchange            
         rate, avoid or reduce supplementary withholding taxes and, upon the          
         ultimate sale of the investment, remit the proceeds of the sale free         
         of tax up to the amount of registered foreign capital. In February           
         1987, when Brazil declared a temporary moratorium on interest                
         payments on its debt, foreign investors possessing a certificate of          
         registration were still able to receive dividends outside Brazil at          
         the official exchange rate.                                                  
              Petitioner had several options with respect to its 1986 blocked         
         deposits:22  (1) Hold the blocked deposits and participate in the            
         debt restructuring process; (2) sell the deposits on the secondary           
         market to another party; or (3) convert the deposits into an equity          
         interest in a Brazilian company pursuant to the Central Bank's debt-         
         equity conversion program.  The only options that would reduce               
         petitioner's blocked deposit holdings and decrease its foreign debt          
         exposure were selling the debt on the secondary market for cash or           
         swapping the debt for equity in a Brazilian company.                         
              C. Papel e Celulose Catarinense, S.A.                                   
              Petitioner decided to engage in a debt-equity conversion and            
         in that regard began examining investment possibilities in Brazilian         
         companies. In November 1986, petitioner received an Information              



               22   Petitioner could only use 1986 deposits to participate            
          in the debt-equity conversion at issue in this case.  These                 
          deposits were governed by the 1984 and 1986 DFA's.                          




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