Income Taxes
The significant components of income tax expense from continuing operations were as follows.
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Year ended December 31, ($ in millions) | 2025 | | 2024 | | 2023 |
| Income from continuing operations before income tax expense | | | | | |
| Domestic | $ | 1,031 | | | $ | 817 | | | $ | 1,086 | |
| Foreign | 20 | | | 19 | | | 17 | |
| Total income from continuing operations | 1,051 | | | 836 | | | 1,103 | |
| Current income tax expense | | | | | |
| U.S. federal | 226 | | | 107 | | | 85 | |
| Foreign | 6 | | | 6 | | | 5 | |
| State and local | 135 | | | 26 | | | 36 | |
| Total current expense | 367 | | | 139 | | | 126 | |
| Deferred income tax (benefit) expense | | | | | |
| U.S. federal | (47) | | | 53 | | | 26 | |
| Foreign | — | | | 1 | | | (1) | |
| State and local | (121) | | | (26) | | | (7) | |
| Total deferred (benefit) expense | (168) | | | 28 | | | 18 | |
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| Total income tax expense from continuing operations | $ | 199 | | | $ | 167 | | | $ | 144 | |
A reconciliation of income tax expense from continuing operations with the amounts at the statutory U.S. federal income tax rate is shown in the following table.
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| 2025 | | 2024 | | 2023 |
Year ended December 31, ($ in millions) | Amount | Percent | | Amount | Percent | | Amount | Percent |
| Statutory U.S. federal tax expense | $ | 221 | | 21 | % | | $ | 175 | | 21 | % | | $ | 232 | | 21 | % |
| Domestic federal reconciling items | | | | | | | | |
| Nontaxable or nondeductible items | | | | | | | | |
| Nondeductible FDIC premium expenses | 32 | | 3 | | | 34 | | 4 | | | 33 | | 3 | |
| Goodwill impairment | 15 | | 1 | | | 5 | | 1 | | | — | | — | |
| Other (a) | 6 | | 1 | | | 4 | | 1 | | | 3 | | — | |
| Tax credits | | | | | | | | |
| Low-income housing tax credits (b) | (55) | | (5) | | | (40) | | (5) | | | (37) | | (3) | |
| Research and development credits | (36) | | (3) | | | (3) | | — | | | (5) | | — | |
| Foreign tax credits (c) | 11 | | 1 | | | (1) | | — | | | 367 | | 33 | |
| Other | (1) | | — | | | — | | — | | | (7) | | (1) | |
| Changes in valuation allowances (d) | (13) | | (1) | | | (14) | | (2) | | | (476) | | (43) | |
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| Effects of cross-border tax laws | 3 | | — | | | 4 | | — | | | 4 | | — | |
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| State & local income taxes, net of federal income tax benefit (e) | 14 | | 1 | | | 16 | | 2 | | | 31 | | 3 | |
| Foreign tax effects | | | | | | | | |
| Canada | 2 | | — | | | 3 | | — | | | 1 | | — | |
| Changes in unrecognized tax benefits | — | | — | | | (16) | | (2) | | | (2) | | — | |
| Total income tax expense from continuing operations | $ | 199 | | 19 | % | | $ | 167 | | 20 | % | | $ | 144 | | 13 | % |
(a)Includes tax effects of share-based payment awards.
(b)Includes investment amortization. Refer to Note 1 for additional information on the accounting for investments in tax credit structures using the proportional amortization method.
(c)Includes tax expense associated with the expiration of unused foreign tax credits.
(d)Includes tax benefits related to the reduction of valuation allowance associated with the expiration of unused foreign tax credits.
(e)For the year ended December 31, 2025, state taxes in New York and Florida made up the majority of the tax effect in this category, compared to state taxes in New York, Florida, and Texas, and state taxes in Florida, Maryland and Georgia, for the years ended December 31, 2024, and 2023, respectively.
For the years ended December 31, 2025, and 2024, consolidated income tax expense from continuing operations was largely driven by pretax earnings and nondeductible FDIC premium expenses, partially offset by an income tax benefit related to various tax credits. For the year ended December 31, 2023, consolidated income tax expense from continuing operations was largely driven by pretax earnings, partially offset by the release of the valuation allowance on foreign tax credit carryforwards as well as an income tax benefit related to various tax credits. The release of the valuation allowance was primarily driven by the identification and execution of a tax planning strategy allowing for additional utilization of foreign tax credits.
We record rehabilitation, energy, and clean vehicle tax credits as part of our ITC category. Our ITCs are generally accounted for using the deferral method and recognized as a reduction of the corresponding asset value. However, ITCs that qualify for proportional amortization treatment are accounted for using the flow-through method and are recognized as a reduction to current income tax expense.
The significant components of deferred tax assets and liabilities are reflected in the following table.
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December 31, ($ in millions) | 2025 | | 2024 |
| Deferred tax assets | | | |
| Adjustments to securities and hedging transactions (a) | $ | 820 | | | $ | 1,080 | |
| Tax credit carryforwards | 690 | | | 679 | |
| Adjustments to loan value | 751 | | | 420 | |
| State and local taxes | 352 | | | 301 | |
| Fixed assets | 272 | | | 257 | |
| Internally generated intangible assets | 168 | | | 107 | |
| Other | 332 | | | 347 | |
| Gross deferred tax assets | 3,385 | | | 3,191 | |
| Valuation allowance | (122) | | | (138) | |
| Deferred tax assets, net of valuation allowance | 3,263 | | | 3,053 | |
| Deferred tax liabilities | | | |
| Lease transactions | 434 | | | 653 | |
| Deferred acquisition costs | 374 | | | 380 | |
| Long-term debt | 58 | | | 62 | |
| Other | 71 | | | 52 | |
| Gross deferred tax liabilities | 937 | | | 1,147 | |
| Net deferred tax assets (b) | $ | 2,326 | | | $ | 1,906 | |
(a)Securities include deferred tax assets related to available-for-sale securities, held-to-maturity securities, and equity securities. There were $613 million and $882 million of deferred tax assets related to available-for-sale securities, at December 31, 2025, and 2024, respectively.
(b)Amounts include $2.3 billion and $1.9 billion of net deferred tax assets included in other assets on our Consolidated Balance Sheet for tax jurisdictions in a total net deferred tax asset position at December 31, 2025, and 2024, respectively, and $8 million and $10 million included in accrued expenses and other liabilities on our Consolidated Balance Sheet for tax jurisdictions in a total net deferred tax liability position at December 31, 2025, and 2024, respectively.
As of each reporting date, we consider existing evidence, both positive and negative, that could impact our view with regard to future realization of deferred tax assets. We continue to believe it is more likely than not that the benefit for certain foreign tax credit carryforwards and state net operating loss carryforwards will not be realized. In recognition of this risk, we continue to provide a partial valuation allowance on the deferred tax assets relating to these carryforwards, and it is reasonably possible that the valuation allowance may change in the next 12 months.
The following table summarizes net deferred tax assets including related valuation allowances at December 31, 2025.
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| ($ in millions) | | Deferred tax asset | | Valuation allowance | | Net deferred tax asset | | Years of expiration |
| Tax credit carryforwards | | | | | | | | |
| General business credits | | $ | 664 | | | $ | — | | | $ | 664 | | | 2044 - 2045 |
| Foreign tax credits | | 26 | | | (13) | | | 13 | | | 2027 - 2035 |
| Total tax credit carryforwards | | 690 | | | (13) | | | 677 | | | |
| Tax loss carryforwards | | | | | | | | |
| Net operating losses — state | | 110 | | | (109) | | | 1 | | | 2026 - Indefinite |
| Net operating losses — federal | | 6 | | | — | | | 6 | | | 2028 - Indefinite |
| Total U.S. federal and state tax loss carryforwards | | 116 | | | (109) | | | 7 | | | |
| Other net deferred tax assets | | 1,642 | | | — | | | 1,642 | | | n/a |
| Net deferred tax assets | | $ | 2,448 | | | $ | (122) | | | $ | 2,326 | | | |
n/a = not applicable
As of December 31, 2025, we have recognized insignificant deferred tax liabilities for incremental U.S. federal taxes that stem from temporary differences related to investment in foreign subsidiaries or corporate joint ventures as there is no assertion of indefinite reinvestment outside of the United States.
The following table provides a reconciliation of the beginning and ending amount of unrecognized tax benefits.
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| ($ in millions) | 2025 | | 2024 | | 2023 |
| Balance at January 1, | $ | 77 | | | $ | 91 | | | $ | 46 | |
| Increases related to positions taken during the current year | 91 | | | — | | | — | |
| Increases related to positions taken during prior years | 1 | | | 6 | | | 48 | |
| Decreases related to positions taken during prior years | — | | | (20) | | | (2) | |
| Settlements | (1) | | | — | | | (1) | |
| Expiration of statute of limitations | — | | | — | | | — | |
| Balance at December 31, | $ | 168 | | | $ | 77 | | | $ | 91 | |
Included in the unrecognized tax benefits balances are some items, the recognition of which would not affect the effective tax rate, such as the tax effect of certain temporary differences and the portion of gross state unrecognized tax benefits that would be offset by the tax benefit of the associated U.S. federal deduction. The balance of unrecognized tax benefits that, if recognized, would affect our effective tax rate was $152 million, $64 million, and $75 million for the years ended December 31, 2025, 2024, and 2023, respectively.
We recognize accrued interest and penalties related to uncertain income tax positions in interest expense and other operating expenses, respectively. As of December 31, 2025, the cumulative accrued balance for interest and penalties was $11 million, and interest and penalties of $4 million were accrued during the year ended December 31, 2025. As of December 31, 2024, the cumulative accrued balance for interest and penalties was $7 million, and penalties of $1 million were accrued during the year ended December 31, 2024. As of December 31, 2023, the cumulative accrued balance for interest and penalties was $6 million, and interest and penalties of $3 million were accrued during the year ended December 31, 2023.
We file tax returns in the U.S. federal jurisdiction and various states and foreign jurisdictions. Our most significant operations are in the United States and Canada. The oldest tax years that remain subject to examination for those jurisdictions are 2019 and 2011, respectively.
The following table provides a disaggregation of the amount of cash paid for income taxes, net of refunds. | | | | | | | | | | | | | | | | | |
Year ended December 31, ($ in millions) | 2025 | | 2024 | | 2023 |
| U.S. federal | $ | 220 | | | $ | 107 | | | $ | (65) | |
| U.S. state and local | | | | | |
| Florida | 22 | | | * | | 8 | |
| California | 18 | | | * | | * |
| Other | 92 | | | 16 | | | 32 | |
| Foreign | | | | | |
| Canada | * | | 12 | | | * |
| Other | 7 | | | — | | | (2) | |
| Total income taxes paid (net of refunds) | $ | 359 | | | $ | 135 | | | $ | (27) | |
* = jurisdiction below the disaggregation threshold for the period presented and not separately disclosed.