Riggs National Corporation & Subsidiaries - Page 35




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         page in Joint Exhibit 692-ZN(23), setting forth (1) the “withholding         
         tax imposed”, (2) the “40-percent pecuniary benefit” the Central             
         Bank received, and (3) the purported “balance (60 percent) of actual         
         withholding tax paid” by the Central Bank, on its September 1985             
         phase II CGA, tranche I interest payments to petitioner and other            
         foreign lenders, is contained infra in appendix B.  (The information         
         from this schedule page concerning the Central Bank’s September 27,          
         1985, phase II CGA, tranche I net interest remittance of $17,441.66          
         (U.S.) to petitioner, is discussed in our findings.)  Indeed, (1)            
         the Morgan Bank letter dated January 21, 1986 (Joint Exhibit 694-            
         ZP(6), pertinent portions of which are quoted in our findings), and          
         (2) petitioner’s own “comptroller’s memorandum” dated February 20,           
         1986 (Joint Exhibit 695-ZQ(4), pertinent portions of which are               
         quoted in our findings), reflect that these Central Bank schedule            
         pages enclosed in Mr. Oliveira’s November 19, 1985, letter, covered          
         phase II CGA, tranche I through tranche VII interest payments for            
         the period from “June 28, 1985 to September 27, 1985".  The Morgan           
         Bank letter and the comptroller’s memorandum each further confirm            
         that the Central Bank had reported “receiving” a “40-percent                 
         pecuniary benefit” in connection with its purported withholding tax          
         payments on those September 27, 1985, phase II CGA interest                  
         payments.                                                                    
              Although Joint Exhibit 697-ZS (which summarizes and lists the           
         related DARF’s and other documents issued in connection with the             






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