- 38 - payments. See supra note 16. In comparison, as was noted supra note 17, the Central Bank’s letter of September 6, 1985 (Joint Exhibit 692-ZN(22)), states the Central Bank was transmitting DARF’s covering phase II CGA interest payments that had been made by the Central Bank in January, March, April, and June 1985. Indeed, one of the Central Bank schedule pages in Exhibit 692-ZN(22) covers various interest payments made to petitioner and other foreign lenders on January 16, 1985. In preparing this schedule page covering those January 16, 1985, interest payments, the Central Bank used an exchange rate of 3,381 cruzeiros to $1 (U.S.), not an exchange rate of 7,772 cruzeiros to $1 (U.S).19 As was previously discussed, the latter exchange rate of 7,772 cruzeiros to $1 (U.S.) applicable on September 27, 1985, was used in preparing the Central Bank schedules in Exhibit 692-ZN(23). See infra appendices A and B. Notwithstanding petitioner’s argument to the contrary, the Central Bank schedules that Mr. Oliveira (a FIRCE division head) 19 This Central Bank schedule page (in Exhibit 692-ZN(22)) reflects that with respect to the Jan. 16, 1985, phase II CGA interest payment of $18,465 (U.S.) to petitioner, the Central Bank computed the “grossed-up interest paid” to be 83,240,220 cruzeiros. Considering the gross-up formula the Central Bank employed, we calculate the Central Bank on Jan. 16, 1985, had used an exchange rate of 3,381 cruzeiros to $1 (U.S.). In other words, that was the applicable exchange rate the Central Bank used in order to compute as follows that amount of “grossed-up interest paid” on its $18,465 (U.S.) net interest remittance to petitioner: 83,240,220 cruzeiros = $18,465 (U.S.) X 3,381 (cruzeiros per dollar) 1 - 25% withholding tax ratePage: Previous 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 Next
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