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To: Chief Executive Officers of All National Banks and Federal Savings Associations, Department and Division Heads, All Examining Personnel, and Other Interested Parties

Description: Joint Statement


The Office of the Comptroller of the Currency (OCC), the Board of Governors of the Federal Reserve System, and the Federal Deposit Insurance Corporation (collectively, the agencies) are jointly issuing an addendum to the “Interagency Policy Statement on Income Tax Allocation in a Holding Company Structure.”1  The purpose of the addendum is to ensure that insured depository institutions (IDI) in a consolidated group maintain appropriate relationships regarding the payment of taxes and treatment of tax refunds.


  • The addendum instructs IDIs and their holding companies to ensure their tax-allocation agreements (1) expressly state that the holding companies are acting as agents for the IDIs, and (2) are consistent with certain requirements of sections 23A and 23B of the Federal Reserve Act.
  • The addendum includes a sample paragraph that IDIs may include in their tax-allocation agreements to facilitate the agencies’ instructions.

Note for Community Banks

The addendum is applicable to all OCC-supervised institutions in a holding company structure. Institutions may benefit from the ability to use a sample paragraph included in the addendum.

Further Information

Contact Gary Jeffers, Counsel, or Steven Key, Assistant Director, Bank Activities and Structure Division, at (202) 649-5500.

Amy S. Friend
Senior Deputy Comptroller and Chief Counsel


 1 63 Fed. Reg. 64757, November 23, 1998.

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