The District Court for the Middle District of Tennessee granted a motion to dismiss a tax refund suit relating to cryptocurrency staking rewards on mootness grounds after the IRS issued the refund.
A joint OCC, Federal Reserve Board and FDIC proposal to establish requirements for tax allocation agreements between institutions and their holding companies in a consolidated tax filing group was published in the Federal Register.
The OCC, Treasury, Federal Reserve Board and FDIC proposed a joint rulemaking to establish requirements for tax allocation agreements between institutions and their holding companies in a consolidated tax filing group.
The Board of Governors of the Federal Reserve System, FDIC, and Office of the Comptroller of the Currency (the "Agencies") jointly issued an Addendum to the "Interagency Policy Statement on Income Tax Allocation in a Holding Company". The Addendum was issued to ensure that insured depository institutions ("IDIs") in a consolidated group maintain an appropriate relationship regarding the payment of taxes and treatment of tax refunds. The Addendum instructs IDIs and their holding companies to review and revise their tax allocation agreements and ensure that the agreements expressly acknowledge
The Federal Reserve, FDIC and OCC (collectively, the "federal banking regulators") have submitted for comment a proposed joint supplemental guidance on income tax allocation agreements involving holding companies and insured depository institutions ("IDIs"). The proposed guidance is intended to supplement an interagency policy statement on income tax allocation issued by the federal banking regulators in 1998, which provided that a holding company receiving a tax refund from a taxing authority obtain such funds as agent for its subsidiary IDIs and affiliates. The proposed guidance would