Tax Allocation Agreements

News & Analysis as of

Allocation, Due Diligence, and More Record Keeping! New Draft Regulations on New York State’s Corporate Income Tax Allocation

2014 brought significant corporate income tax reform to New York State. This year, 2015, followed suit and brought many of those same corporate income tax reforms to New York City. To quote Donald Trump, these reforms are...more

Status Update on Targeted Allocation Regulations

I’m at the ABA Tax conference this week and one of this morning’s first panels included a discussion of hot topics in partnerships. Curtis Wilson, IRS Associate Chief Counsel in Passthroughs and Special Industries,...more

IRS Slams Profits Interests In Lieu of Management Fees and More

The IRS issued the much anticipated proposed regulations that severely curtail the practice of a fund manager waiving management fees in exchange for a share of future partnership profits. In essence the regulations tighten...more

CDFI Fund Releases Updated Compliance FAQ

On Friday January 2, the CDFI Fund released an updated Frequently Asked Questions document for New Markets Tax Credit (“NMTC”) questions relating to certification, compliance monitoring, and evaluation. The updated FAQ...more

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

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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