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on june 13th bank regulatory agencies jointly adopted new rules regarding income tax allocation agreements made between financial institutions and their parent holding companies these new rules will require almost all existing agreements to be modified before talking about the new rules lets review what a tax allocation agreement is entities that are related through common ownership typically file a consolidated federal tax return instead of having each entity file a separate tax return when a group files a consolidated tax return the entities are required to have a tax allocation agreement that states among other things the manner in which each entity will calculate its share of the total tax and how overpayments of tax are to be handled among the related parties in recent years disputes have arisen between holding companies in bankruptcy and failed banks owned by these holding companies regarding the ownership of tax refunds due in some of these disputes courts found that the tax re