Riggs National Corporation & Subsidiaries, f.k.a. Riggs National Bank and Subsidiaries - Page 19

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          Central Bank had paid on behalf of an entire group of foreign               
          lenders subject to a particular withholding tax rate (i.e., a               
          12.5-percent withholding tax rate, a 15-percent withholding tax             
          rate, or a 25-percent withholding tax rate).                                
               The Central Bank sent to Morgan Bank (which served as the              
          agent bank of foreign lenders that included petitioner) group               
          DARFs reporting the aggregate withholding tax the Central Bank              
          had paid on behalf of that group of lenders.  The Central Bank              
          enclosed with the DARFs supporting schedules setting forth with             
          respect to each foreign lender:  (1) The net interest remitted,             
          (2) the grossed-up interest; (3) the withholding tax imposed, (4)           
          the 40-percent pecuniary benefit the Central Bank received, and             
          (5) the “60-percent balance of actual withholding tax paid”.                
          Notwithstanding that on June 28, 1985, the pecuniary benefit had            
          been reduced to zero, the Central Bank continued to report to the           
          foreign lenders that it received a pecuniary benefit equal to 40            
          percent of the withholding tax imposed on its post-June 28, 1985,           
          interest remittances to them.                                               
               The supporting schedules reported that the Central Bank                
          withheld and paid Brazilian income taxes of $166,415 for 1984 and           
          $181,272 for 1985 in connection with debt interest remittances to           
          petitioner.  The supporting schedules reported that the Central             
          Bank received pecuniary benefits of $66,566 for 1984 and $72,509            








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