Taxation of Financial Institutions
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LexisNexis Matthew Bender is proud to present the Second Edition of Taxation of Financial Institutions, completely updated, rewritten and reorganized by the authors at KPMG LLP as of December 2013.
This product includes numerous new chapters and clarifies the rapidly changing area of financial institution taxation with a wealth of information on tax laws, regulations, IRS rules, and insight from the top professionals in the field.
Filled with time-saving examples, this set includes discussion of:
• The Consolidated Appropriations Act of 2021 and related modifications to the Paycheck Protection Program.
• Final regulations implementing legislative changes to IRC § 448, as well as the small business provisions in IRC §§ 263A, 460, and 471.
• Proposed interbank offered rate regulations (the “Proposed IBOR Regulations”) and Revenue Procedure 2020-44.
• Final regulations regarding tax treatment of notional principal contracts.
• Revenue Procedure 2021-3, which lists areas in which the IRS does not agree to provide a ruling request or determination letter.
• Treas. Reg. Section 1.1502-21(c)(1)(i) and the cumulative register rule, and Treas. Reg. Section 1.1502-21(b)(3)(ii)(B) and related split-waiver elections, including examples.
• Further clarification of final regulations in terms of the determination of base erosion payments.
• IRC Section 864(f), which allows a taxpayer to elect a worldwide allocation of interest expense.
• The 2021 163(j) Regulations, which narrow the definition of interest, modify the anti-avoidance rule, provide guidance on the term “paid or accrued,” and define the term “adjusted taxable income” by reference to “tentative taxable income” — a new defined term.
• FinCEN’s intention to propose an amendment to the regulations that would include a virtual currency account as a reportable FBAR account. [FinCEN Notice 2020-2.]
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Table of contents
PART I: INTRODUCTION
Chapter 1 History, Overview, and Definitions--Banks and Thrifts
PART II: BANK TAX ACCOUNTING
Chapter 2 Accounting Methods
Chapter 3 Accounting Periods
PART III: INCOME AND DEDUCTION ITEMS
Chapter 4 Debt Instruments--Interest, OID, and Significant Modifications
Chapter 5 Securities Investment and Derivative Transactions
Chapter 6 Municipal Obligations
Chapter 7 Bad Debts
Chapter 8 Foreclosures
Chapter 9 Net Operating Losses
Chapter 10 Leases
Chapter 11 [Reserved]
PART IV: SPECIAL INDUSTRY PRACTICES
Chapter 12 Financial Institutions as Securities Dealers
Chapter 13 Loan Sales and Structured Financings
Chapter 14 Common Trust Funds
Chapter 15 Business Combinations and Holding Companies
Chapter 16 Tax Issues Related to FDIC-Assisted Acquisitions of Troubled Banks
Chapter 17 Net Investment Income
Chapter 18 [Reserved]
PART V: TAXATION OF INTERNATIONAL BANKS
Chapter 19 Taxation of Foreign Banks' U.S. Branches, Agencies, and Subsidiaries
Chapter 20 International Taxation of U.S. Banks
Chapter 21 Information Reporting and Backup Withholding
Chapter 22 [Reserved]
PART VI: STATE TAXATION OF FINANCIAL INSTITUTIONS
Chapter 23 State Taxation of Financial Institutions--Overview
Chapter 24 State Taxation of Financial Institutions--Nexus
Chapter 25 State and Local Income Taxes
Chapter 26 State Franchise Taxes
Chapter 27 Sales and Use Taxes
Chapter 28 Selected State Taxes Imposed on Financial Institutions
PART VII: MISCELLANEOUS TOPICS
Chapter 29 Financial Institutions as S Corporations
Chapter 30 Transfer Pricing
PART VIII: TABLES AND INDEX