Bank Holding Companies
December 14, 1998
Circular No. 11118

Uniform Policy on Income Tax Allocations in a Holding Company Structure

To All Bank Holding Companies and Others Concerned in the Second Federal Reserve District:

The Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of Thrift Supervision have adopted a uniform interagency policy statement regarding intercompany tax allocation agreements for banking organizations and savings associations that file an income tax return as members of a consolidated group.

In general, intercorporate tax settlements between an institution and its parent company should be conducted in a manner that is no less favorable to the institution than if it were a separate taxpayer.

The interagency notice on the policy statement, as published in the Federal Register of November 23, 1998, is available as a file (pdf - 27kb).