- 18 - 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 notPage: Previous 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 Next
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