+--------+---+------------------+---------+---------------------------+---+
| # O    | # |                  |         |                           | # |
|        | # |                  |         |                           |   |
| ##     | # |                  |         |                           |   |
|        | # |                  |         |                           | # |
|        |   |                  |         |                           |   |
|        | O |                  |         |                           |   |
|        | C |                  |         |                           | # |
|        | C |                  |         |                           | # |
|        |   |                  |         |                           |   |
|        | 9 |                  |         |                           |   |
|        | 8 |                  |         |                           |   |
|        | - |                  |         |                           |   |
|        | 5 |                  |         |                           |   |
|        | 6 |                  |         |                           |   |
+--------+---+------------------+---------+---------------------------+---+
|        | * |                  |         |                           |   |
|        | * |                  |         |                           |   |
|        | O |                  |         |                           |   |
|        | C |                  |         |                           |   |
|        | C |                  |         |                           |   |
|        | B |                  |         |                           |   |
|        | U |                  |         |                           |   |
|        | L |                  |         |                           |   |
|        | L |                  |         |                           |   |
|        | E |                  |         |                           |   |
|        | T |                  |         |                           |   |
|        | I |                  |         |                           |   |
|        | N |                  |         |                           |   |
|        | * |                  |         |                           |   |
|        | * |                  |         |                           |   |
+--------+---+------------------+---------+---------------------------+---+
| ## Com |   |                  |         |                           |   |
| ptroll |   |                  |         |                           |   |
| er of  |   |                  |         |                           |   |
| the Cu |   |                  |         |                           |   |
| rrency |   |                  |         |                           |   |
|        |   |                  |         |                           |   |
| > A    |   |                  |         |                           |   |
| dminis |   |                  |         |                           |   |
| trator |   |                  |         |                           |   |
| > of   |   |                  |         |                           |   |
| > Na   |   |                  |         |                           |   |
| tional |   |                  |         |                           |   |
| >      |   |                  |         |                           |   |
|  Banks |   |                  |         |                           |   |
+--------+---+------------------+---------+---------------------------+---+
| ## Su  |   | Intercompany Tax | #       | Joint Policy Statement on |   |
| bject: |   | Allocation       | # Descr | Intercompany Tax          |   |
|        |   | Agreements       | iption: | Allocation Agreements     |   |
+--------+---+------------------+---------+---------------------------+---+

**TO:** Chief Executive Officers of National Banks, Department and
Division Heads, and all Examining Personnel

On November 23, 1998, the Office of the Comptroller of the Currency, the
Federal Reserve Board, the Federal Deposit Insurance Corporation, and
the Office of Thrift Supervision published the attached joint policy
statement on intercompany tax allocation agreements. The policy
statement provides guidance regarding the allocation and payment of
income taxes by banks that file an income tax return as members of a
consolidated group. In general, intercorporate tax settlements between a
bank and its parent should result in no less favorable treatment to the
bank than if it had filed its income tax return as a separate taxpayer.

In addition, the policy statement recommends that each depository
institution have a written, comprehensive tax allocation agreement
addressing intercorporate tax policies and procedures.

For more information, contact Eugene Green, at (202) 874-4933 or Tom
Rees, at (202) 874-5411, Office of the Chief Accountant.

\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

Kevin J. Bailey

Deputy Comptroller

Core Policy

Attachment B [63 FR
64757](http://www.occ.treas.gov/fr/fedregister/63fr64757.pdf)

\[http://www.occ.treas.gov/fr/fedregister/63fr64757.pdf\]