Riggs National Corporation & Subsidiaries - Page 33




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         purported payment of withholding tax on petitioner’s behalf.  As             
         determined in our findings, the Central Bank reported that it was            
         continuing to “receive” a “pecuniary benefit” in connection with its         
         purported withholding tax payments on the foreign lenders’ behalf            
         on its post-June 28, 1985, restructuring debt interest remittances           
         to them, notwithstanding that the Brazilian Government had reduced           
         the pecuniary benefit to zero on June 28, 1985.  In arguing to the           
         contrary, petitioner misinterprets the evidence of record.  Further,         
         petitioner erroneously asserts that Mr. Oliveira’s letter of                 
         November 19, 1985 (Joint Exhibit 692-ZN(23)), covers an earlier              
         January 1985 phase II CGA interest payment.  Petitioner’s  erroneous         
         assertion regarding that letter rests solely upon an incorrect entry         
         and likely typographical error in the parties’ summary exhibit,              
         Joint Exhibit 697-ZS.                                                        
              Curiously, petitioner overlooks the seven September 1985 phase          
         II CGA interest payments that were remitted after the Brazilian              
         Government had reduced the pecuniary benefit to zero on June 28,             
         1985.  Joint Exhibit 697-ZS correctly lists Joint Exhibit 692-ZN(23)         
         (Mr. Oliveira’s letter of November 19, 1985, and its attachments)            
         as covering those seven September 1985 interest payments.  Moreover,         
         the Central Bank schedule pages in Exhibit 692-ZN(23)16 show that,           



               16   These include Central Bank schedule pages covering the            
          phase II CGA, tranche I, tranche II, tranche IV, tranche V,                 
          tranche VI, and tranche VII interest payments made to petitioner            
          and other foreign lenders on Sept. 27, 1985.                                





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