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On June 13th, bank regulatory agencies introduced new rules on income tax allocation agreements between financial institutions and their parent holding companies. These rules will require modifications to almost all existing agreements. Tax allocation agreements are essential for entities filing consolidated federal tax returns, outlining how each entity calculates its share of taxes and handles tax overpayments. Disputes have arisen between holding companies in bankruptcy and failed banks over ownership of tax refunds, with some courts ruling in favor of the holding companies.
