15. Income Taxes

For the years ended December 31, 2025, 2024 and 2023, income from continuing operations before income tax expense and the provision (benefit) for income taxes from continuing operations were comprised of the following:

Year Ended December 31, 

(dollars in thousands)

  ​

2025

  ​

2024

  ​

2023

Income from continuing operations before income tax expense

Federal

$

309,133

$

292,602

$

309,174

Foreign (1)

45,110

Total income from continuing operations before income tax expense

$

354,243

$

292,602

$

309,174

Income tax expense (benefit) from continuing operations

Current tax expense:

Federal

$

57,235

$

57,006

$

66,123

State and local

20,163

16,754

21,724

Foreign

916

Total current

78,314

73,760

87,847

Deferred tax expense (benefit):

Federal

4,861

(4,756)

(8,387)

State and local

(5,198)

(6,531)

(5,269)

Foreign

Total deferred

(337)

(11,287)

(13,656)

Total income tax expense:

Federal

62,096

52,250

57,736

State and local

14,965

10,223

16,455

Foreign

916

Total provision for income taxes

$

77,977

$

62,473

$

74,191

(1) Foreign income from continuing operations includes income from the Company’s Guam and Saipan operations.

The Company files Federal and state income tax returns for its subsidiaries. The Company’s subsidiary also files income tax returns in Guam, Saipan and certain other state jurisdictions. The Company had a current income tax receivable due from various jurisdictions of $35.0 million and $25.5 million as of December 31, 2025 and 2024, respectively, for its share of consolidated and combined tax overpayments that had not yet been received.

The components of net deferred income tax assets and liabilities at December 31, 2025 and 2024, were as follows:

December 31, 

(dollars in thousands)

  ​

2025

  ​

2024

Assets:

Deferred compensation expense

$

56,557

$

52,192

Allowance for credit losses and nonperforming assets

56,247

51,922

Lease liabilities

16,623

16,808

Investment securities

138,260

171,258

State income taxes

2,594

1,939

Total deferred income tax assets

270,281

294,119

Liabilities:

Leases

(8,760)

(8,457)

Deferred income

(16,799)

(7,151)

Lease right-of-use assets

(15,753)

(16,041)

Intangible assets

(1,075)

(973)

Other

(29,703)

(30,292)

Total deferred income tax liabilities

(72,090)

(62,914)

Net deferred income tax assets

$

198,191

$

231,205

Net deferred income tax assets were included in other assets in the consolidated balance sheets as of December 31, 2025 and 2024.

Realization of deferred tax assets is dependent on sufficient taxable income being generated in the future and, although realization is not assured, the Company believes it is more likely than not that all of the deferred tax assets will be realized. However, if estimates of future taxable income decrease, a reduction to the amount of deferred tax assets considered realizable could result.

The following analysis reconciles the Federal statutory income tax rate to the effective income tax rate for the year ended December 31, 2025:

Year Ended December 31, 

2025

(dollars in thousands)

  ​

Amount

  ​

Percent

Federal statutory income tax expense and rate

$

74,391

21.00

%

Federal reconciling items

Tax credits:

Low-income housing tax credits

(5,139)

(1.45)

Other credits

(3,295)

(0.93)

Nontaxable or nondeductible items:

Tax-exempt BOLI income

(4,310)

(1.22)

Other nontaxable or nondeductible items

368

0.10

Cross-border tax laws

(217)

(0.06)

Other adjustments

953

0.27

State and local taxes, net of federal income tax benefit(1)

11,822

3.34

Foreign tax effects

37

0.01

Changes in unrecognized tax benefits

3,367

0.95

Income tax expense and effective income tax rate

$

77,977

22.01

%

(1) State taxes in Hawaii and California made up the majority (greater than 50 percent) of the tax effect in this category.

The following analysis reconciles the Federal statutory income tax rate to the effective income tax rate for the years ended December 31, 2024 and 2023:

2024

2023

(dollars in thousands)

  ​

Amount

  ​

Percent

Amount

  ​

Percent

Federal statutory income tax expense and rate

$

61,446

21.00

%

$

64,927

21.00

%

State and local taxes, net of federal income tax benefit

8,077

2.76

13,000

4.20

Tax credits

(4,388)

(1.50)

(4,506)

(1.46)

Nontaxable income

(5,604)

(1.92)

(6,691)

(2.16)

Other

2,942

1.01

7,461

2.42

Income tax expense and effective income tax rate

$

62,473

21.35

%

$

74,191

24.00

%

The Company is subject to examination by the Internal Revenue Service (“IRS”) and tax authorities in states in which the Company has significant business operations. The tax years under examination and open for examination vary by jurisdiction. Currently, refund claims and tax returns for certain years are being reviewed by state jurisdictions. No material adjustments are anticipated as a result of these examinations and reviews. The Company’s income tax returns for 2022 and subsequent tax years generally remain subject to examination by U.S. federal and foreign jurisdictions, and 2021 and subsequent years are subject to examination by state taxing authorities.

A reconciliation of the amount of unrecognized tax benefits is as follows for the years ended December 31, 2025, 2024 and 2023:

Year Ended December 31, 

2025

2024

2023

Interest

Interest

Interest

and

and

and

(dollars in thousands)

  ​

Tax

  ​

Penalties

  ​

Total

  ​

Tax

  ​

Penalties

  ​

Total

  ​

Tax

  ​

Penalties

  ​

Total

Balance at beginning of year

$

179,008

$

27,384

$

206,392

$

185,461

$

26,584

$

212,045

$

183,751

$

22,474

$

206,225

Additions for current year tax positions

203

203

653

653

629

629

Additions for Reorganization Transactions

2,653

2,653

2,717

2,717

3,155

3,155

Additions for prior years' tax positions:

New uncertain tax positions identified

2,256

2,256

2,220

2,220

Accrual of interest and penalties

1,391

1,391

1,253

1,253

1,221

1,221

Reductions for prior years' tax positions:

Expiration of statute of limitations

(1,355)

(376)

(1,731)

(4,408)

(1,280)

(5,688)

(1,139)

(266)

(1,405)

Resolutions with tax authorities

(2,698)

(1,890)

(4,588)

Balance at December 31, 

$

180,112

$

31,052

$

211,164

$

179,008

$

27,384

$

206,392

$

185,461

$

26,584

$

212,045

Included in the balance of unrecognized tax benefits for the years ended December 31, 2025, 2024 and 2023, was $55.7 million, $51.8 million and $56.4 million, respectively, of unrecognized tax benefits that, if recognized, would impact the effective tax rate.

In connection with the Reorganization Transactions discussed below, the Company recorded unrecognized tax benefits and interest and penalties of $121.4 million and $7.0 million, respectively. Included in the balance of the unrecognized tax benefits as of December 31, 2025, was $141.2 million attributable to tax refund claims with respect to tax years 2005 through 2013 and 2015 in the State of California. Such refund claims were filed by the Company in 2015, 2019 and 2021, on behalf of the Company and its affiliates, including BOW, concerning the determination of taxes for which no benefit is currently recognized. On February 1, 2023, Bank of Montreal acquired Bank of the West from BNP Paribas SA. This transaction, and the resulting change in ownership, could affect the unrecognized tax benefits related to the years when the Company was included in consolidated and combined returns with Bank of the West.

The Company recognizes interest and penalties attributable to both unrecognized tax benefits and undisputed tax adjustments in the provision for income taxes. For the years ended December 31, 2025, 2024 and 2023, the Company recorded $4.1 million, $4.0 million and $4.2 million, respectively, of net expense attributable to interest and penalties. The Company had a liability of $33.1 million and $29.1 million as of December 31, 2025 and 2024, respectively, accrued for interest and penalties, of which $31.1 million and $27.4 million as of December 31, 2025 and 2024, respectively, were attributable to unrecognized tax benefits and the remainder was attributable to tax adjustments which are not expected to be in dispute.

Prior to the Reorganization Transactions, the Company filed consolidated U.S. Federal and combined state tax returns that incorporated the tax receivables and unrecognized tax benefits of FHB and BOW. The consummation of the Reorganization Transactions did not relieve the Company of the pre-Reorganization Transactions tax receivables and unrecognized tax benefits recognized by BOW that were included in the Company's consolidated and combined tax returns. As a result, on April 1, 2016, the Company recorded $72.8 million related to current tax receivables, $116.6 million related to unrecognized tax benefits, and an indemnification payable of $28.6 million. As of December 31, 2025 and 2024, the Company maintained balances of $130.5 million related to current tax receivables. As of December 31, 2025 and 2024, the Company maintained balances of $161.1 million and $159.0 million, respectively, related to unrecognized tax benefits, and an indemnification receivable of $30.6 million and $28.5 million, respectively. Additionally, in connection with the Reorganization Transactions, the Company has incurred certain tax-related liabilities related to the distribution of its interest in BWHI amounting to $95.4 million. The amount necessary to pay the distribution taxes (net of the expected federal tax benefit of $33.4 million) was paid by BNPP to the Company on April 1, 2016. The Company reported total distribution taxes of $92.1 million in the 2016 tax returns of various state and local jurisdictions, and reimbursed BWHI approximately $2.1 million pursuant to a tax sharing agreement entered into on April 1, 2016 and pursuant to certain tax allocation agreements entered into among the parties. The Company expects that any future adjustment to such taxes will be similarly reimbursed to, or funded by, BNPP or its affiliates. Accordingly, the assumption of the pre-Reorganization Transactions tax receivables, unrecognized tax benefits and distribution tax liabilities and the offsetting indemnification receivables or payables were reflected as equity contributions and distributions on April 1, 2016. The reimbursement of distribution taxes to BWHI was also reflected as an adjustment to equity. If there are any future adjustments to the indemnified tax receivables or unrecognized tax benefits, an offsetting adjustment to the indemnification receivables or payables will be recorded to the provision for income taxes and other noninterest income or expense. For the years ended December 31, 2025, 2024 and 2023, the Company recorded $2.1 million, $2.1 million and $2.5 million, respectively, of such adjustments through the provision for income taxes and noninterest income. In addition, for the year ended December 31, 2024, the Company recorded $3.8 million of such adjustments through the provision for income taxes and noninterest expense.

The following table presents income taxes paid, net of income tax refunds, for the year ended December 31, 2025:

Year Ended

(dollars in thousands)

  ​

December 31, 2025

Federal taxes paid

$

31,892

State and local taxes paid:

California

5,380

Other

3,707

Total state and local taxes paid

9,087

Foreign taxes paid

Total income taxes paid

$

40,979

Income taxes paid, net of income tax refunds, for the years ended December 31, 2024 and 2023 were $36.3 million and $54.0 million, respectively.

Historical Timeline

Fiscal YearFiled
2025Feb 27, 2026Showing above
2024Feb 28, 2025
2023Feb 28, 2024
2022Feb 24, 2023
2021Feb 25, 2022
2020Feb 25, 2021
2019Feb 28, 2020
2018Feb 28, 2019
2017Feb 28, 2018
2016Mar 15, 2017

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.