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in computing and setting forth the Central Bank’s purported
withholding tax payments on its September 1985 phase II CGA interest
payments to various foreign lenders (including petitioner), the
Central Bank used exchange rates that were applicable on September
27, 1985, and not exchange rates applicable in January 1985. For
instance, in computing the “withholding tax imposed” on the
September 27, 1985, phase II CGA, tranche I interest remittance of
$17,441.66 (U.S.) to petitioner, the Central Bank employed an
exchange rate of 7,772 cruzeiros to $1 (U.S.). A copy of the
Central Bank foreign currency conversion rate chart (in Joint
Exhibit 692-ZN(23)) enclosed in Mr. Oliveira’s letter of November
19, 1985, is contained infra in appendix A. See also infra note 19
concerning the exchange rate of 3,381 cruzeiros to $1 (U.S.) that
the Central Bank used to compute the “grossed-up interest paid” on
its January 16, 1985, phase II CGA interest remittance to
petitioner.
Contrary to petitioner’s argument, the Central Bank schedule
pages in Joint Exhibit 692-ZN(23) reflect that the Central Bank
itself continued to report to the foreign lenders that it received
a “pecuniary benefit” equal to 40 percent of the “withholding tax
imposed” on its September 1985 phase II CGA interest payments to
them, even though after June 28, 1985, no Brazilian borrower
actually received a pecuniary benefit in connection with its
interest remittances abroad. A copy of the Central Bank schedule
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