- 35 - 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 thePage: Previous 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 Next
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