News & Analysis as of

Bank Holding Company Income Taxes

Kilpatrick

High Court Tax Refund Ruling Indicates State Law Authority

Kilpatrick on

On Feb. 25, The U.S. Supreme Court issued its decision in Rodriguez v. Federal Deposit Insurance Corp., a case involving a dispute between (1) the trustee in bankruptcy of a defunct bank holding company, and (2) the FDIC, as...more

Baker Donelson

October 31 Amendment Deadline for Bank Holding Company Tax Allocation Agreements

Baker Donelson on

On June 19, 2014, the federal banking agencies issued a final Addendum to their Interagency Policy Statement on Income Tax Allocation in a Holding Company Structure which may require non-S corporation bank holding company...more

Dickinson Wright

Bank Regulators Require Changes To Tax Allocation Agreements

Dickinson Wright on

Acting in response to divergent results in recent court decisions, the Federal bank regulatory agencies have adopted an Addendum to their longstanding rules regarding income tax allocation agreements between insured...more

Orrick - Finance 20/20

Three Agencies Seek Comment on Joint Supplemental Guidance on Income Tax Allocation Agreements

On December 19, Fed, FDIC and OCC issued a statement seeking comment on supplemental guidance on income tax allocation agreements involving holding companies and insured depository institutions. ...more

Katten Muchin Rosenman LLP

Agencies Issue Proposed Guidance on Tax Allocation Agreements Between Insured institutions and Their Holding Companies

On December 19, banking agencies including the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation (FDIC) and the Office of the Comptroller of the Currency (collectively, the agencies)...more

McDermott Will & Emery

District Court Accords Work Product Protection to Taxpayer Documents Prepared during a Transaction’s Planning Stages

McDermott Will & Emery on

The U.S. District Court for the District of Delaware recently interpreted the work product privilege in a manner favorable to taxpayers, ruling that documents can be prepared “in anticipation of litigation” even if created...more

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