At December
31, 2025, the
net deferred tax
asset of the
U.S. operations amounted
to $
614.8
million with
a valuation allowance
of
$
386.6
million, for a net deferred tax asset
of $
228.2
million. The Corporation evaluates the realization of the
deferred tax assets by
taxing jurisdiction,
on a quarterly basis.
The U.S. Operations have generated taxable income each of the last three years,
with 2025
having the highest
taxable income. These financial
results are objectively verifiable
positive evidence. Additionally,
the Corporation
considered as negative
evidence, inconsistency
in
performance trends,
including lower than
anticipated results
in
recent periods.
Also, management considered
the uncertainty in
predicting future taxable
income, as
given the impact
of external factors
such as
changes in
macroeconomic conditions,
geopolitical issues,
and shifts
in monetary
policy.
In
addition, management
evaluated the
expiration period of the NOLs carried forward
which begin to expire in 2028.
As of
December 31,
2025, after weighting
all positive
and negative evidence,
the Corporation concluded
that it
is more
likely than
not that approximately $
228.2
million of the deferred tax assets from the
U.S. operations, comprised mainly of net operating losses,
will
be
realized.
The
Corporation based
this
determination
on
its
estimated
taxable
income
available
to
realize
the
deferred
tax
assets for
the remaining carryforward
periods, together
with the
historical level of
book income
adjusted by permanent
differences
and taxable income. Management will continue to
monitor and review the U.S. operation’s
results, including recent earnings trends,
pre-tax
earnings
forecasts,
new
tax
initiatives,
and
performance
indicators
such
as
net
income
versus
forecast,
targeted
loan
growth,
net
interest
income
margin,
changes
in
deposit
costs,
allowance
for
credit
losses,
charge-offs,
NPLs
inflows,
and
NPA
balances. Significant changes, or a combination of changes, could positively or
negatively impact the amount of deferred tax assets
to be realized in the future.
At December 31,
2025, the Corporation’s
net deferred tax
assets related to
its Puerto Rico
operations amounted to
$
662.3
The Corporation’s
Puerto Rico
Banking operation
has strong
historical record
of profitability.
This is
considered a
strong piece
of
objectively verifiable
positive evidence
that outweighs
any negative
evidence considered
by Management
in the
evaluation of
the
realization of the deferred tax assets. Based on this evidence and Management’s estimate of future taxable income, the Corporation
has concluded that it is more likely than not that
such net deferred tax assets
of the Puerto Rico Banking operations
will be realized.
The Holding Company operation has been in a
cumulative loss position in recent years.
Management expects these losses will be a
trend
in
future
years.
This
objectively
verifiable
negative
evidence is
considered
by
Management strong
negative
evidence that
suggests that
income in
future years
will be
insufficient to
support the
realization of
all deferred
tax assets.
After weighting
of all
positive
and
negative evidence,
Management concluded
as
of
the reporting
date,
that
it
is
more
likely
than
not that
the
Holding
Company will not be
able to realize any
portion of the deferred tax
assets. Accordingly, the
Corporation has maintained a valuation
allowance on the deferred tax assets of $
78.2
million as of December 31, 2025.