I
NCOME TAXESThe following disclosures reflect the adoption of ASU 2023-09. Refer to Note 1 Accounting Policies for additional information related to our adoption of this ASU.
The income from continuing operations before income tax expense, disaggregated between domestic and foreign sources, along with the components of income tax expense are as follows:
Table 106: Income from Continuing Operations Before Income Tax Expense and Components of Income Tax Expense
| | | | | | | | | | | | | | | | | | | | |
Year ended December 31 In millions | 2025 | | 2024 | | 2023 | |
| Income from continuing operations before income tax expense | | | | | | |
| Domestic | $ | 8,378 | | | $ | 7,033 | | | $ | 6,624 | | |
| Foreign | 108 | | | 209 | | | 112 | | |
| Total | $ | 8,486 | | | $ | 7,242 | | | $ | 6,736 | | |
| Components of income tax expense | | | | | | |
| Current | | | | | | |
| Federal | $ | 1,346 | | | $ | 1,046 | | | $ | 992 | | |
| State | 173 | | | 221 | | | 320 | | |
| Foreign | 10 | | | 52 | | | 29 | | |
| Total current | 1,529 | | | 1,319 | | | 1,341 | | |
| Deferred | | | | | | |
| Federal | (6) | | | — | | | (145) | | |
| State | (36) | | | (29) | | | (103) | | |
| Foreign | 2 | | | (1) | | | (4) | | |
| Total deferred | (40) | | | (30) | | | (252) | | |
| Total | $ | 1,489 | | | $ | 1,289 | | | $ | 1,089 | | |
Significant components of deferred tax assets and liabilities are as follows:
Table 107: Deferred Tax Assets and Liabilities
| | | | | | | | | | | | | | |
| In millions | December 31, 2025 | | December 31, 2024 | |
| Deferred tax assets | | | | |
| Net unrealized losses on securities and financial instruments | $ | 1,137 | | | $ | 2,098 | | |
| Allowance for loan and lease losses | 1,072 | | | 1,105 | | |
| Lease obligations | 494 | | | 475 | | |
| Compensation and benefits | 312 | | | 312 | | |
| Allowance for unfunded lending related commitments | 201 | | | 177 | | |
| | | | |
| Accrued expenses | 65 | | | 188 | | |
| | | | |
| Other | 238 | | | 340 | | |
| Total gross deferred tax assets | 3,519 | | | 4,695 | | |
| Valuation allowance | (24) | | | (23) | | |
| Total deferred tax assets | $ | 3,495 | | | $ | 4,672 | | |
| Deferred tax liabilities | | | | |
| Leasing | 798 | | | 919 | | |
| Fixed assets | 324 | | | 397 | | |
| Right of use assets | 434 | | | 412 | | |
| Mortgage servicing rights | 424 | | | 434 | | |
| Goodwill and intangibles | 246 | | | 249 | | |
| | | | |
| | | | |
| Other | 455 | | | 472 | | |
| Total deferred tax liabilities | $ | 2,681 | | | $ | 2,883 | | |
| Net deferred tax asset | $ | 814 | | | $ | 1,789 | | |
A reconciliation between the statutory and effective tax rates follows:
Table 108: Reconciliation of Statutory and Effective Tax Rates
| | | | | | | | | | | | | | | | | | | | |
Year ended December 31 Dollars in millions | 2025 | 2024 | 2023 |
| Amount | Percent | Amount | Percent | Amount | Percent |
| Statutory tax rate | $ | 1,782 | | 21.0 | % | $ | 1,521 | | 21.0 | % | $ | 1,415 | | 21.0 | % |
| State and local income tax, net of federal (national) income tax effect (a) | 198 | | 2.3 | | 200 | | 2.8 | | 162 | | 2.4 | |
| Foreign tax effects | (12) | | (0.1) | | 12 | | 0.2 | | (1) | | — | |
| | | | | | |
| | | | | | |
| Tax credits | | | | | | |
| LIHTC | (138) | | (1.6) | | (102) | | (1.4) | | (97) | | (1.4) | |
| NMTC | (35) | | (0.4) | | (76) | | (1.1) | | (130) | | (1.9) | |
| Other | (84) | | (1.0) | | (92) | | (1.3) | | (65) | | (1.0) | |
| | | | | | |
| Nontaxable or nondeductible items | | | | | | |
| Tax-exempt interest | (93) | | (1.1) | | (103) | | (1.4) | | (117) | | (1.7) | |
| Other | (39) | | (0.5) | | (77) | | (1.1) | | 1 | | — | |
| Changes in unrecognized tax benefits | (69) | | (0.8) | | 11 | | 0.2 | | 51 | | 0.8 | |
| Other (b) | (21) | | (0.3) | | (5) | | (0.1) | | (51) | | (0.8) | |
| Tax claims and adjustments | — | | — | | — | | — | | (79) | | (1.2) | |
| Income tax expense/effective tax rate | $ | 1,489 | | 17.5 | % | $ | 1,289 | | 17.8 | % | $ | 1,089 | | 16.2 | % |
(a)The states and local jurisdictions accounting for the majority of total state and local income tax expense include California, New Jersey, Illinois, New York and New York City for all periods presented.
(b)Includes an insignificant amount related to the effect of cross-border tax laws for all periods presented.
The net operating loss carryforwards at December 31, 2025 and 2024 follow:
Table 109: Net Operating Loss Carryforwards
| | | | | | | | | | | | | | | | | | | | |
| Dollars in millions | December 31, 2025 | | December 31, 2024 | | Expiration | |
| Net Operating Loss Carryforwards (a): | | | | | | |
| | | | | | |
| State | $ | 582 | | | $ | 585 | | | 2026-2039 | |
(a)There were no federal net operating loss carryforwards at December 31, 2025 or 2024.
The majority of tax credit carryforwards expire in 2030-2045 and were insignificant at both December 31, 2025 and 2024. We anticipate that we will be able to fully utilize our tax credit carryforwards. Some state net operating loss carryforwards are from acquired entities and utilization is subject to various statutory limitations.
Retained earnings included $0.1 billion at both December 31, 2025 and 2024 in allocations for bad debt deductions of former thrift subsidiaries for which no income tax has been provided. Under current law, if certain subsidiaries use these bad debt reserves for purposes other than to absorb bad debt losses, they will be subject to Federal income tax at the current corporate tax rate.
A reconciliation of the beginning and ending balance of unrecognized tax benefits is as follows:
Table 110: Change in Unrecognized Tax Benefits
| | | | | | | | | | | | | | | | | | | | |
| In millions | 2025 | | 2024 | | 2023 | |
| Balance of gross unrecognized tax benefits at January 1 | $ | 365 | | | $ | 368 | | | $ | 318 | | |
| Increases: | | | | | | |
| Positions taken during a current period | 7 | | | 23 | | | 20 | | |
| | | | | | |
| Positions taken during a prior period | 2 | | | 35 | | | 35 | | |
| Decreases: | | | | | | |
| | | | | | |
| | | | | | |
| Settlements with taxing authorities | (40) | | | (1) | | | (4) | | |
| Reductions resulting from lapse of statute of limitations | (64) | | | (60) | | | (1) | | |
| Balance of gross unrecognized tax benefits at December 31 | 270 | | | 365 | | | 368 | | |
| Favorable impact if recognized | $ | 243 | | | $ | 314 | | | $ | 306 | | |
We are subject to U.S. federal income tax as well as income tax in most states and some foreign jurisdictions. Table 111 summarizes the status of significant IRS examinations.
Table 111: IRS Tax Examination Status
| | | | | | | | | | | | | | |
| Year(s) | | Status at December 31, 2025 | |
| | | | |
| Federal | 2020-2021 | | Under exam | |
In addition, we are under continuous examinations by various state taxing authorities. With few exceptions, we are no longer subject to state and local and foreign income tax examinations by taxing authorities for periods before 2019. For all open audits, any potential adjustments have been considered in establishing our unrecognized tax benefits as of December 31, 2025.
Our policy is to classify interest and penalties associated with income taxes as income tax expense. For 2025 and 2024, the amount of gross interest and penalties recorded on our Consolidated Income Statement was insignificant. The amount of accrued interest and penalties recorded on our Consolidated Balance Sheet was insignificant at December 31, 2025 and $0.1 billion at December 31, 2024.
The income taxes paid (refunded), disaggregated between federal, state and foreign sources are as follows:
Table 112: Income Taxes Paid, Net of Refunds
| | | | | | | | | | | | | | | | | | | | |
Year ended December 31 In millions | 2025 | | 2024 | | 2023 | |
| U.S. federal income taxes paid (refunded) | $ | 385 | | | $ | 132 | | | $ | (185) | | |
| U.S. state and local income taxes paid | | | | | | |
| New York City | $ | 45 | | | $ | 48 | | | $ | 25 | | |
| California | 46 | | | 42 | | | 29 | | |
| New Jersey | * | | 28 | | | 44 | | |
| Illinois | * | | 20 | | | 36 | | |
| Florida | * | | * | | 22 | | |
| New York | * | | * | | 32 | | |
| Maryland | * | | * | | 20 | | |
| Massachusetts | * | | * | | 12 | | |
| Oregon | * | | * | | 10 | | |
| Indiana | * | | * | | 9 | | |
| Kentucky | * | | * | | 8 | | |
| All other states | 171 | | | 86 | | | 67 | | |
| Total | $ | 262 | | | $ | 224 | | | $ | 314 | | |
| Foreign income taxes paid | | | | | | |
| United Kingdom | * | | $ | 28 | | | $ | 27 | | |
| Canada | * | | * | | 9 | | |
| Other | 57 | | | 5 | | | * | |
| Total | $ | 57 | | | $ | 33 | | | $ | 36 | | |
| Total income taxes paid, net of refunds | $ | 704 | | | $ | 389 | | | $ | 165 | | |
* Amounts are below the 5% threshold for disaggregation.