Taxation of Financial Institutions

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.

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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.

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:

•  Revenue Procedure 2021-34, which provides the procedures for taxpayers to obtain automatic consent to change their methods of accounting.

•  Revenue Procedure 2021-35, which modifies Revenue Procedure 2013-26 to reflect the changes made to the treatment of certain credit card fees by IRC Section 451(b).

•  The Consolidated Appropriations Act of 2021 and related modifications to the Paycheck Protection Program.

•  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.

•  The 2021 IRC Section 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.”

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Table of contents

VOLUME 1

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]

VOLUME 2

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