Tax Allocation Agreements

News & Analysis as of

October 31 Amendment Deadline for Bank Holding Company Tax Allocation Agreements

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

Deadline Looming to Amend Your Tax Allocation Agreement

The October 31st deadline to review and revise your tax allocation agreement is rapidly approaching. Banks and their holding companies need to ensure their agreements are in compliance with new regulatory guidance that,...more

Final Supplemental Guidance on Income Tax Allocation Agreements: Why It’s Important to Act Now

Almost every bank and its holding company (“HC”) conduct business with each other, typically through an agreement whereby one performs services for the other in return for some consideration. The bank, for example, may...more

Supplemental Interagency Guidance on Tax Allocation Agreements

The federal bank regulators recently issued additional guidance on intercompany income tax allocation agreements between holding companies and their depository institution subsidiaries. Intended to clarify the ownership of...more

Bank Holding Companies Must Review Their Tax Allocation Agreements With Subsidiary Banks Now!

Taxes remain a certainty in life, but in an effort to reduce confusion regarding the ownership of tax refunds—particularly in light of court opinions reaching varying conclusions when considering failed banks—the Board of...more

Federal Banking Agencies Issue Final Version of Addendum to Interagency Policy Statement on Income Tax Allocation

The FRB, FDIC and OCC (collectively, the “Agencies”) issued a final version of an addendum (the “Addendum”) to their “Interagency Policy Statement on Income Tax Allocation in a Holding Company Structure” (the “Policy...more

Bank Regulators Require Changes To Tax Allocation Agreements

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

Banking Bulletin: Regulators To Mandate Amendments To Tax Allocation Agreements

On December 19, 2013, the Federal Reserve, OCC, and FDIC issued a Proposed Addendum to the Interagency Policy Statement on Income Tax Allocation in a Holding Company Structure. The agencies are currently soliciting comments,...more

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