- 21 - with respect to each specific September 27, 1985, Central Bank interest remittance to a foreign lender: (1) The withholding tax imposed, (2) the “40-percent pecuniary benefit” the Central Bank received, and (3) the “60-percent balance of actual withholding tax paid”. For instance, with respect to the Central Bank’s September 27, 1985, phase II CGA, tranche I interest remittance to petitioner, the Central Bank schedule reflected the following: Net Interest Grossed-Up “Pecuniary “Balance Remittance Int. Paid Tax Benefit” Tax Paid” (U.S. $) (Cruzeiros)1 (Cruzeiros) (Cruzeiros) (Cruzeiros) 17,441.66 180,742,108.69 45,185,527.17 18,074,210.86 27,111,316.30 1 The Central Bank used the following formula to compute this amount: Net int. remittance Grossed-up = (foreign currency) x Applic. exchange rate int. paid 1 - Withholding tax rate (cruzeiros) (On Sept. 27, 1985, the Central Bank used an exchange rate of $1 (U.S.) to 7,772 cruzeiros.) On or about January 21, 1986, Morgan Bank forwarded copies of the aforementioned DARF’s and schedules that the Central Bank had issued in connection with its September 27, 1985, phase II CGA interest remittances to each of the foreign lenders participating in the phase II CGA. The letter, dated January 21, 1986, by which Morgan Bank enclosed these documents to the foreign lenders, stated, in pertinent part:Page: Previous 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 Next
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