Riggs National Corporation & Subsidiaries - Page 21




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         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:                                                           











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