Riggs Nat'l Corp. & Subsidiaries v. Commissioner
United States Tax Court
P regularly made and participated in loans to borrowers located in foreign countries, including Brazil. It was one of hundreds of banks that were involved in the restructuring of Brazil's foreign debt.
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P regularly made and participated in loans to borrowers located in foreign countries, including Brazil. It was one of hundreds of banks that were involved in the restructuring of Brazil's foreign debt. As required by Brazilian law, various non-tax-immune Brazilian borrowers paid Brazilian withholding tax on their net loan interest remittances to P during 1980 through 1986. Although the Brazilian Supreme Court had held that, under Article 19 of the Brazilian Constitution, tax-immune Brazilian governmental entities, like the Central Bank, were not liable to pay withholding tax on their net loan…
1Opinion of the Court
RIGGS NATIONAL CORPORATION & SUBSIDIARIES, (f.k.a. RIGGS NATIONAL BANK AND SUBSIDIARIES), Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Riggs Nat'l Corp. & Subsidiaries v. Commissioner
Docket No. 24368-89.
United States Tax Court
107 T.C. 301; 1996 U.S. Tax Ct. LEXIS 49; 107 T.C. No. 18;
December 10, 1996, Filed
Decision will be entered under Rule 155.
P regularly made and participated in loans to borrowers located in foreign countries, including Brazil. It was one of hundreds of banks that were involved in the restructuring of Brazil's foreign debt.
As required by Brazilian law, various…
2Cases cited16 opinions
- Banco Nacional De Cuba v. SabbatinoSupreme Court of the United States · 1964
- Wichita Term. El. Co. v. Commissioner of Int. R.Court of Appeals for the Tenth Circuit · 1947
- W. S. Kirkpatrick & Co. v. Environmental Tectonics Corp., InternationalSupreme Court of the United States · 1990
- Biddle v. CommissionerSupreme Court of the United States · 1938
- American Chicle Co. v. United StatesSupreme Court of the United States · 1942
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