Riggs National Corporation & Subsidiaries - Page 18




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              On its books, Banco do Brazil made entries reflecting: (1)              
         Transfers of Central Bank tax payments to Banco do Brazil’s Banking          
         Reserves Account at the Central Bank, (2) collections of Federal             
         Government tax receipts, and (3) deposits of Federal Government tax          
         revenues payable upon demand to the National Treasury.                       
              From the record presented, we cannot determine whether or what          
         entries were made on the respective books of the Central Bank and            
         the National Treasury to reflect the Central Bank’s payment of               
         withholding tax on the restructuring debt remittances.                       
         Consequently, we are unable to determine:  (1) Whether the Central           
         Bank was reimbursed by the National Treasury for the withholding tax         
         payments; or (2) whether the Central Bank received the pecuniary             
         benefit based on the withholding tax payments.  These two matters            
         were raised in the Central Bank’s ruling request and were discussed          
         in the March 1984 Brazilian IRS ruling to the Central Bank.                  
              Beginning in 1984, the Central Bank issued DARF’s to the agent          
         banks of the foreign lenders to whom it transmitted loan payments            
         under the DFA’s and CGA’s, reflecting its withholding tax payments           
         on restructuring debt interest remittances during the relending              
         periods of the DFA’s and CGA’s.  From 1984 through 1988, the Central         
         Bank issued a total of 324 DARF’s to these agent banks.  As                  
         explained more fully infra, these 324 DARF’s were group DARF’s.              
              In connection with remitting a particular DFA or CGA interest           
         payment to an individual foreign lender, the Central Bank did not            






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