Riggs National Corporation & Subsidiaries - Page 8




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          remitted the proceeds (in foreign currency) to the borrower via a           
          commercial bank in Brazil.  The Brazilian bank converted the                
          foreign currency into Brazilian currency by means of an exchange            
          contract, whereby the borrower sold the foreign currency to the             
          bank for Brazilian currency at the official exchange rate                   
          periodically set by the Central Bank.                                       
               The Brazilian borrower received a certificate of registration          
          that enabled the borrower to effect payment of interest, and                
          principal, in the foreign currency in which the loan was made.  On          
          each payment date, the borrower purchased foreign currency from a           
          Brazilian bank at the official exchange rate.  The Brazilian bank           
          then tendered the foreign currency to the foreign lender.                   
          C.  Payment of the Withholding Tax Generally                                
               Where withholding tax was required, Brazilian law prohibited           
          remittance of an interest payment to a foreign lender without proof         
          of payment of the withholding tax on the interest remitted abroad.          
          Under Brazilian law, the borrower initiated payment of the                  
          withholding tax by submitting a Documento de Arrecadacao de                 
          Receitas Federais (DARF) and the accompanying tax payment to a              
          commercial Brazilian bank.  The bank making the interest payment in         













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Last modified: May 25, 2011