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RIGGS NAT. CORP. & SUBSIDIARIES v. C.I.R.

No. 98-1039.

163 F.3d 1363 (1999)

RIGGS NATIONAL CORPORATION & SUBSIDIARIES, Appellant, v. COMMISSIONER OF INTERNAL REVENUE SERVICE, Appellee.

United States Court of Appeals, District of Columbia Circuit.

Decided January 12, 1999.

Attorney(s) appearing for the Case

Thomas C. Durham argued the cause for appellant. With him on the briefs were Joel V. Williamson, Kim Marie Boylan, and Stephen M. Feldhaus.

Charles Bricken, Attorney, United States Department of Justice, argued the cause for appellee. With him on the brief were Loretta C. Argrett, Assistant Attorney General, and David English Carmack, Attorney.

Stephen D. Gardner was on the brief for amicus curiae National Foreign Trade Council, Inc.

Before: WALD, SILBERMAN, and TATEL, Circuit Judges.

Opinion for the Court filed by Circuit Judge SILBERMAN.

SILBERMAN, Circuit Judge:

Riggs Bank, asserting that it had paid taxes to the Brazilian government with respect to interest income on loans it had made to the Central Bank of Brazil, claimed foreign tax credits under § 901 of the Internal Revenue Code. The Commissioner disallowed the credits on the theory that Riggs was not "legally liable" for the tax under Brazilian law, and the Tax Court denied...

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