FIRST CITIZENS BANCSHARES INC /DE/FCNCA
FIRST CITIZENS BANCSHARES INC /DE/ Income Taxes Disclosure
NOTE 19 — INCOME TAXES
The provision (benefit) for income taxes for the year ended December 31, 2025, 2024 and 2023 is comprised of the following:
Provision (Benefit) for Income Taxes
| dollars in millions | Year Ended December 31, | ||||||||||||||||
| 2025 | 2024 | 2023 | |||||||||||||||
| Current U.S. federal income tax provision | $ | 585 | $ | 649 | $ | 400 | |||||||||||
| Deferred U.S. federal income tax (benefit) / provision | (38) | 68 | 46 | ||||||||||||||
| Total federal income tax provision | 547 | 717 | 446 | ||||||||||||||
| Current state and local income tax provision | 286 | 157 | 372 | ||||||||||||||
| Deferred state and local income tax benefit | (79) | (71) | (222) | ||||||||||||||
| Total state and local income tax provision | 207 | 86 | 150 | ||||||||||||||
| Total non-U.S. income tax provision | 11 | 12 | 15 | ||||||||||||||
| Total provision for income taxes | $ | 765 | $ | 815 | $ | 611 | |||||||||||
A reconciliation from the U.S. Federal statutory rate to BancShares’ actual effective income tax rate for the year ended December 31, 2025, 2024 and 2023 is presented below. Income tax expense (benefit) includes, if applicable, federal, state and foreign taxes:
Effective Tax Rate Reconciliation
| dollars in millions | Year Ended December 31, | ||||||||||||||||||||||||||||||||||
| 2025 | 2024 | 2023 | |||||||||||||||||||||||||||||||||
| Amount | Percent | Amount | Percent | Amount | Percent | ||||||||||||||||||||||||||||||
| Pretax income domestic | $ | 2,926 | $ | 3,551 | $ | 12,043 | |||||||||||||||||||||||||||||
| Pretax income foreign | 45 | 41 | 34 | ||||||||||||||||||||||||||||||||
| Total pretax income | $ | 2,971 | $ | 3,592 | $ | 12,077 | |||||||||||||||||||||||||||||
| US federal statutory income tax rate | $ | 624 | 21.0 | % | $ | 754 | 21.0 | % | $ | 2,536 | 21.0 | % | |||||||||||||||||||||||
| Domestic federal taxes | |||||||||||||||||||||||||||||||||||
| Tax credits | |||||||||||||||||||||||||||||||||||
| Low income housing | (44) | (1.5) | (29) | (0.8) | (17) | (0.1) | |||||||||||||||||||||||||||||
| Other | (26) | (0.9) | (16) | (0.4) | (6) | — | |||||||||||||||||||||||||||||
| Nontaxable and nondeductible items | |||||||||||||||||||||||||||||||||||
| Gain on acquisition | — | — | — | — | (1,874) | (15.5) | |||||||||||||||||||||||||||||
| FDIC premiums | 36 | 1.2 | 24 | 0.7 | 23 | 0.2 | |||||||||||||||||||||||||||||
| Other | 4 | 0.1 | — | — | 2 | — | |||||||||||||||||||||||||||||
| Other | 3 | 0.1 | 3 | 0.1 | (7) | (0.1) | |||||||||||||||||||||||||||||
| Domestic state and local income taxes, net of federal effect | 149 | 5.0 | 33 | 0.9 | (51) | (0.4) | |||||||||||||||||||||||||||||
| Foreign tax effects | 2 | 0.1 | 2 | — | 5 | — | |||||||||||||||||||||||||||||
| Changes in unrecognized tax benefits | 17 | 0.6 | 44 | 1.2 | — | — | |||||||||||||||||||||||||||||
| Total effective tax rate | $ | 765 | 25.7 | % | $ | 815 | 22.7 | % | $ | 611 | 5.1 | % | |||||||||||||||||||||||
On July 4, 2025, President Trump signed into law H.R. 1, referred to as the One Big Beautiful Bill Act (the “OBBBA”). The OBBBA contains several provisions that impact corporate taxation. The enactment of the OBBBA did not have a material impact on our tax rate or results of operations.
BancShares permanently reinvested eligible earnings of certain foreign subsidiaries and accordingly, does not accrue any U.S. or foreign taxes that would be due if those earnings were repatriated. As of December 31, 2025, this assertion resulted in an unrecognized net deferred tax liability of approximately $28 million.
Jurisdictions which make up the majority of state and local income tax are as follows:
State and Local Jurisdictions
| Year Ended December 31, | ||||||||||||||
| 2025 | 2024 | 2023 | ||||||||||||
| California | California | California | ||||||||||||
| New York | New York | New York | ||||||||||||
| New York City | North Carolina | Massachusetts | ||||||||||||
The tax effects of temporary differences that give rise to deferred income tax assets and liabilities at December 31, 2025 and 2024 are presented below:
Components of Deferred Income Tax Assets and Liabilities
| dollars in millions | December 31, 2025 | December 31, 2024 | |||||||||
| Deferred Tax Assets: | |||||||||||
| Allowance for loan and lease losses | $ | 466 | $ | 500 | |||||||
| Net unrealized loss on investment securities available for sale | 67 | 226 | |||||||||
| Deferred compensation | 129 | 128 | |||||||||
| Capitalized costs | 21 | 110 | |||||||||
| Lease liabilities | 77 | 84 | |||||||||
| Tax credits | 75 | 79 | |||||||||
| Net operating loss carry forwards | 67 | 76 | |||||||||
| Other | 104 | 112 | |||||||||
| Total gross deferred tax assets | 1,006 | 1,315 | |||||||||
| Deferred Tax Liabilities: | |||||||||||
| Basis difference in loans | (1,886) | (2,243) | |||||||||
| Operating leases | (1,938) | (1,847) | |||||||||
| Loans and direct financing leases | (311) | (329) | |||||||||
| Pension assets | (161) | (129) | |||||||||
| Right of use assets for operating leases | (64) | (73) | |||||||||
| Other | (130) | (149) | |||||||||
| Total deferred tax liabilities | (4,490) | (4,770) | |||||||||
| Total net deferred tax liability before valuation allowances | (3,484) | (3,455) | |||||||||
| Less: valuation allowances | (17) | (17) | |||||||||
| Net deferred tax liability after valuation allowances | $ | (3,501) | $ | (3,472) | |||||||
Net Operating Loss Carryforwards and Valuation Adjustments
As of December 31, 2025, BancShares has DTAs totaling $67 million on its global net operating losses (“NOLs”). This includes: (1) DTAs of $50 million (net of federal expense) relating to cumulative state NOLs of $1.15 billion, including amounts of reporting entities that file in multiple jurisdictions, (2) DTAs of $12 million relating to cumulative non-U.S. NOLs of $55 million, and (3) DTAs of $5 million relating to cumulative federal NOLs of $23 million. The U.S. federal NOLs were substantially utilized in 2023 and the remaining federal NOLs are limited under Internal Revenue Code Sec. 382 and begin to expire in 2030. State NOLs begin to expire in 2026 and non-US NOLs will begin to expire in 2041.
As of December 31, 2025, BancShares has DTAs of $75 million from its global tax credits. This includes: (1) DTAs of $50 million from federal tax credits, which BancShares has committed to purchase in 2026, (2) DTAs of $20 million (net of federal expense) from state tax credits, and (3) DTAs of $5 million from non-U.S. tax credits. The federal tax credits begin to expire in 2046, the state tax credits begin to expire in 2026, and the non-U.S. credits begin to expire in 2035.
During 2025, management updated BancShares’ forecast of future U.S. state taxable income. The updated forecast continues to support a valuation allowance of $17 million (net of federal benefit) on U.S. state DTAs relating to certain state NOLs as of December 31, 2025.
BancShares’ ability to recognize DTAs is evaluated on a quarterly basis to determine if there are any significant events that would affect our ability to utilize existing DTAs. If events are identified that affect our ability to utilize our DTAs, changes to the valuation allowance may be required.
Liabilities for Unrecognized Tax Benefits
A reconciliation of the beginning and ending amount of UTBs is as follows:
Unrecognized Tax Benefits
| December 31, 2025 | December 31, 2024 | December 31, 2023 | |||||||||||||||||||||||||||
| dollars in millions | Liabilities for Unrecognized Tax Benefits | Interest / Penalties | Total | Total | Total | ||||||||||||||||||||||||
| Balance at beginning of period | $ | 77 | $ | 9 | $ | 86 | $ | 31 | $ | 30 | |||||||||||||||||||
| Additions for tax positions related to current year | 4 | — | 4 | 8 | — | ||||||||||||||||||||||||
| Additions for tax positions related to prior years | 14 | 6 | 20 | 48 | 5 | ||||||||||||||||||||||||
| Reductions for tax positions of prior years | (17) | — | (17) | — | — | ||||||||||||||||||||||||
| Expiration of statutes of limitations | (2) | — | (2) | (1) | (2) | ||||||||||||||||||||||||
| Settlements | (1) | (1) | (2) | — | (2) | ||||||||||||||||||||||||
| Balance at end of period | $ | 75 | $ | 14 | $ | 89 | $ | 86 | $ | 31 | |||||||||||||||||||
BancShares recognizes tax benefits when it is more likely than not that the position will prevail, based solely on the technical merits under the tax law of the relevant jurisdiction. BancShares will recognize the tax benefit if the position meets this recognition threshold determined based on the largest amount of the benefit that is more than likely to be recognized.
During the year ended December 31, 2025, BancShares recorded a net increase in UTBs, including interest and penalties. The net increase primarily related to additions for tax positions related to prior and current years and was partially offset by the reductions for tax positions of prior years, expiration of statutes of limitations, and settlements.
As of December 31, 2025, the accrued liability for interest and penalties is $14 million. BancShares recognizes accrued interest and penalties on UTBs in income tax expense.
BancShares has UTBs relating to uncertain state tax positions in various state jurisdictions resulting from tax filings submitted to the states. No tax benefit has been recorded for these uncertain tax positions in the consolidated financial statements.
The entire $89 million of UTBs including interest and penalties at December 31, 2025, would lower BancShares’ effective income tax rate, if realized.
Income Taxes Paid
Federal, state, and foreign income taxes paid, net of refunds, for the years ended December 31, 2025, 2024 and 2023 are presented in the following table:
Cash Taxes Paid
| dollars in millions | Year Ended December 31, | ||||||||||||||||
| 2025 | 2024 | 2023 | |||||||||||||||
| U.S. federal | $ | 231 | $ | 207 | $ | 169 | |||||||||||
| U.S. state and local | |||||||||||||||||
| New York | 26 | * | * | ||||||||||||||
| New York City | 24 | * | 27 | ||||||||||||||
| California | * | 231 | 216 | ||||||||||||||
| North Carolina | * | 47 | * | ||||||||||||||
| Massachusetts | * | 43 | 38 | ||||||||||||||
| Illinois | * | 39 | * | ||||||||||||||
| Other | 31 | 194 | 63 | ||||||||||||||
| Total U.S. state and local | 81 | 554 | 344 | ||||||||||||||
| Foreign | 3 | 2 | 1 | ||||||||||||||
| Total taxes paid | $ | 315 | $ | 763 | $ | 514 | |||||||||||
*Immaterial amounts not required to be disclosed and are reflected in “Other.”
Income Tax Audits
BancShares is subject to examinations by the U.S. Internal Revenue Service and other taxing authorities in jurisdictions where BancShares has significant business operations for the years ranging from 2015 through 2025. The tax years under examination vary by jurisdiction. BancShares does not expect completion of those audits to have a material impact on the firm’s financial condition, but it may be material to operating results for a particular period, depending, in part, on the operating results for that period.
The table below presents the earliest tax years that remain subject to examination by major jurisdiction.
| Jurisdiction | December 31, 2025 | ||||
| U.S. Federal | 2022 | ||||
| New York State and City | 2015 | ||||
| North Carolina | 2016 | ||||
| California | 2017 | ||||
| Canada | 2018 | ||||
Historical Timeline
| Fiscal Year | Filed | |
|---|---|---|
| 2025 | Feb 24, 2026 | Showing above |
| 2024 | Feb 21, 2025 | |
| 2023 | Feb 23, 2024 | |
| 2022 | Feb 24, 2023 | |
| 2021 | Feb 25, 2022 | |
| 2020 | Feb 24, 2021 | |
| 2019 | Feb 26, 2020 | |
| 2018 | Feb 20, 2019 | |
| 2017 | Feb 21, 2018 | |
| 2016 | Feb 22, 2017 | |
| 2015 | Feb 24, 2016 | |
About Income Taxes Disclosures
The income tax disclosure reveals how much a company actually pays in taxes versus what the statutory rate would predict. Analysts focus on the effective tax rate (ETR) reconciliation, which breaks down every item driving the gap between the 21% federal rate and the company's reported ETR — including R&D credits, foreign rate differentials, and state taxes. Deferred tax assets (DTAs) and their valuation allowances signal management's confidence in future profitability: a rising allowance suggests the company doubts it can use accumulated tax benefits. Uncertain tax benefit (UTB) reserves quantify exposure to IRS challenges on aggressive positions.
Key signals to watch: sudden ETR drops without clear operational reasons, large increases in valuation allowances, growing UTB balances, and significant unremitted foreign earnings. Post-TCJA, pay attention to GILTI and BEAT provisions that affect multinational tax structures. Compare the cash taxes paid (from the cash flow statement) against the income tax provision to gauge earnings quality.