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NOTES 811 Tax Lawyer, Vol. 53, No. 3 NOTE ACT OF STATE DOCTRINE ALLOWS FOREIGN TAXES ON NET LOAN INTEREST PAID BY A FOREIGN CENTRAL BANK TO QUALIFY FOR FOREIGN TAX CREDIT: RIGGS NATIONAL CORP. V. COMMISSIONER In Riggs National Corp. v. Commissioner,1 the U.S. Court of Appeals for the D.C. Circuit reversed the Tax Court and held that a U.S. bank which received interest payments pursuant to a net loan with the Brazilian Central Bank is entitled to foreign tax credits under section 901 for Brazilian...