INCOME TAXES
For a discussion of our income tax accounting policies and other income tax-related information see Note 2.
The following table presents our U.S. and foreign components of pre-tax income for each respective period.
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| | Year ended September 30, |
| $ in millions | | 2025 | | 2024 | | 2023 |
| U.S. | | $ | 2,608 | | | $ | 2,534 | | | $ | 2,193 | |
| Foreign | | 106 | | | 109 | | | 87 | |
| Pre-tax income | | $ | 2,714 | | | $ | 2,643 | | | $ | 2,280 | |
The following table details the total income tax provision/(benefit) allocation for each respective period.
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| | Year ended September 30, |
| $ in millions | | 2025 | | 2024 | | 2023 |
Included in: | | | | | | |
| Net income | | $ | 579 | | | $ | 575 | | | $ | 541 | |
| Equity, arising from available-for-sale securities recorded through OCI | | 30 | | | 149 | | | 3 | |
Equity, arising from cash flow hedges recorded through OCI | | (2) | | | (12) | | | — | |
Equity, arising from currency translations, net of the impact of net investment hedges recorded through OCI | | 13 | | | — | | | (4) | |
| Total provision for income taxes | | $ | 620 | | | $ | 712 | | | $ | 540 | |
The following table details our provision/(benefit) for income taxes included in net income for each respective period.
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| | Year ended September 30, |
| $ in millions | | 2025 | | 2024 | | 2023 |
| Current: | | | | | | |
| Federal | | $ | 463 | | | $ | 486 | | | $ | 468 | |
| State and local | | 126 | | | 131 | | | 122 | |
| Foreign | | 42 | | | 41 | | | 39 | |
| Total current | | $ | 631 | | | $ | 658 | | | $ | 629 | |
| Deferred: | | | | | | |
| Federal | | (26) | | | (68) | | | (59) | |
| State and local | | (21) | | | (12) | | | (16) | |
| Foreign | | (5) | | | (3) | | | (13) | |
| Total deferred | | $ | (52) | | | $ | (83) | | | $ | (88) | |
Total provision for income taxes included in net income | | $ | 579 | | | $ | 575 | | | $ | 541 | |
The following table details a reconciliation of the provision for income taxes at the U.S. federal statutory income tax rate to our actual provision for income taxes and the effective income tax rate for each respective period.
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| | Year ended September 30, |
| | 2025 | | 2024 | | 2023 |
| $ in millions | | Amount | | Rate | | Amount | | Rate | | Amount | | Rate |
| Provision calculated at statutory rate | | $ | 570 | | | 21.0 | % | | $ | 555 | | | 21.0 | % | | $ | 479 | | | 21.0 | % |
| State income tax, net of federal benefit | | 79 | | | 2.9 | % | | 87 | | | 3.3 | % | | 83 | | | 3.6 | % |
Nondeductible executive compensation | | 18 | | | 0.7 | % | | 13 | | | 0.5 | % | | 13 | | | 0.6 | % |
| Foreign tax rate differential | | 14 | | | 0.5 | % | | 10 | | | 0.4 | % | | 8 | | | 0.4 | % |
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Excess tax benefits related to share-based compensation (1) | | (44) | | | (1.6) | % | | (20) | | | (0.8) | % | | (21) | | | (0.9) | % |
Gains on corporate-owned life insurance policies which are not subject to tax | | (28) | | | (1.0) | % | | (51) | | | (1.9) | % | | (22) | | | (1.0) | % |
Federal tax credits | | (26) | | | (1.0) | % | | (23) | | | (1.0) | % | | (14) | | | (0.7) | % |
Nondeductible fines and penalties (2) | | — | | | — | % | | (6) | | | (0.2) | % | | 18 | | | 0.8 | % |
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| Other, net | | (4) | | | (0.2) | % | | 10 | | | 0.5 | % | | (3) | | | (0.1) | % |
Total | | $ | 579 | | | 21.3 | % | | $ | 575 | | | 21.8 | % | | $ | 541 | | | 23.7 | % |
(1)Excess tax benefits related to share-based compensation were primarily attributable to the increase in fair value of our RSUs between grant date and delivery date which was $200 million, $91 million, and $95 million for the years ended September 30, 2025, 2024, and 2023, respectively.
(2)The year ended September 30, 2024, reflected the favorable impact of a legal and regulatory matters reserve release while the year ended September 30, 2023, reflected the impact of provisions for legal and regulatory matters.
For the years ended September 30, 2025, 2024, and 2023, respectively, we had investment tax credits of $10 million, $20 million, and $11 million primarily related to our equity investments in LIHTC funds and historic tax credit funds, as well as certain renewable energy tax structures. Such tax credits were included in “Federal tax credits” in the preceding table. We also hold equity investments in certain structures which deliver tax credits and other tax benefits that qualify for the application of the proportional amortization method. Such investments are amortized in proportion to the tax benefits received in each year, and the investment amortization and the tax benefits are presented on a net basis within “Provision for income taxes” on our Consolidated Statements of Income and Comprehensive Income. See Note 2 for additional information. For the years ended September 30, 2025, 2024, and 2023, the amortization of renewable energy tax credit investments accounted for under the proportional amortization method was $43 million, $28 million and $86 million, respectively, and we recognized offsetting tax credits of $44 million, $28 million, and $81 million, respectively. For the year ended September 30, 2023, we also recognized other tax benefits related to such investments of $9 million. Such amounts were insignificant for the years ended September 30, 2025 and 2024. For each of the years ended September 30, 2025, 2024, and 2023, the amortization of LIHTC investments accounted for under the proportional amortization method was $3 million, and we recognized offsetting tax credits of $3 million in each year. The amortization of all tax credit investments accounted for under the proportional amortization method, as well as the offsetting tax credits and other related tax benefits were reflected in “Other, net” in the preceding table. As of September 30, 2025, we had $47 million of remaining commitments related to a renewable energy tax credit investment accounted for under the proportional amortization method, which was accrued within “Other payables” on our Consolidated Statements of Financial Condition and is expected to be funded in our fiscal 2026 upon the project satisfying certain conditions. The unamortized equity investment related to this investment was $23 million and was included in “Other assets” on our Consolidated Statements of Financial Condition as of September 30, 2025.
Deferred income taxes are provided for the effects of temporary differences between the tax basis of an asset or liability and its reported amount in the financial statements. These temporary differences result in taxable or deductible amounts in future years. The cumulative effects of temporary differences that give rise to significant portions of the deferred tax asset/(liability) items are detailed in the following table.
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| | September 30, |
| $ in millions | | 2025 | | 2024 |
| Deferred tax assets: | | | | |
| Deferred compensation | | $ | 455 | | | $ | 433 | |
Allowances for credit losses | | 143 | | | 140 | |
| Lease liabilities | | 135 | | | 123 | |
| Unrealized loss associated with available-for-sale securities | | 131 | | | 161 | |
| Accrued expenses | | 43 | | | 46 | |
Net operating losses and credit carryforwards | | 30 | | | 26 | |
| Unrealized loss associated with loan portfolios | | 23 | | | 32 | |
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Property and equipment | | 3 | | | — | |
| Other | | 19 | | | 19 | |
| Total deferred tax assets | | 982 | | | 980 | |
| Less: valuation allowance | | (9) | | | (9) | |
Total deferred tax assets, net of valuation allowance | | 973 | | | 971 | |
| Deferred tax liabilities: | | | | |
ROU lease assets | | (148) | | | (134) | |
| Goodwill and identifiable intangible assets | | (144) | | | (138) | |
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| Property and equipment | | — | | | (44) | |
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| Other | | (10) | | | (8) | |
| Total deferred tax liabilities | | (302) | | | (324) | |
| Net deferred tax assets | | $ | 671 | | | $ | 647 | |
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| Classified as follows in the Consolidated Statements of Financial Condition: | | | | |
| Deferred income taxes, net | | $ | 671 | | | $ | 651 | |
| Other payables | | — | | | (4) | |
| Net deferred tax assets | | $ | 671 | | | $ | 647 | |
We have various tax loss carryforwards that may provide future tax benefits. Related valuation allowances are established in accordance with accounting guidance for income taxes if it is management’s opinion that it is more likely than not that these benefits will not be realized. The following table presents deferred tax assets and valuation allowances relating to carryforwards for the periods indicated.
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| | Year ended September 30, |
| $ in millions | | 2025 | | 2024 | | Expires beginning of fiscal year |
Deferred tax asset: | | | | | | |
U.S. Federal net operating losses (1) | | $ | 5 | | | $ | 8 | | | Indefinitely |
U.S. State net operating losses (1) | | 5 | | | 5 | | | 2028 |
Foreign net operating losses | | 20 | | | 13 | | | 2042 |
Total deferred tax asset related to carryforwards | | $ | 30 | | | $ | 26 | | | |
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Valuation allowance: | | | | | | |
U.S. Federal net operating losses | | $ | 1 | | | $ | 2 | | | |
U.S. State net operating losses | | 5 | | | 5 | | | |
Foreign net operating losses | | 3 | | | 2 | | | |
Net valuation allowance | | $ | 9 | | | $ | 9 | | | |
(1)Both the federal and state net operating loss carryforwards relate to separate company entity filings. As a result, these losses are not able to be utilized in our consolidated filings.
As of September 30, 2025, total deferred tax assets, net of the valuation allowance, aggregated to $973 million. We continue to believe that the realization of our deferred tax assets is more likely than not based on expectations of future taxable income.
As of September 30, 2024, there were $4 million of net deferred tax liabilities included in “Other payables” on our Consolidated Statements of Financial Condition, which primarily arose from entities in the UK, and accordingly were not netted against balances arising from our U.S. entities.
As of September 30, 2025, we considered substantially all undistributed earnings of non-U.S. subsidiaries to be permanently reinvested and have not provided for any U.S. deferred income taxes related to such subsidiaries as we expect our incremental tax cost of repatriating such offshore earnings to not be significant. As of September 30, 2025, we had approximately $669 million of cumulative undistributed earnings attributable to foreign subsidiaries. Because the time and manner of repatriation is uncertain, we cannot determine the impact of local taxes, withholding taxes, and foreign tax credits associated with the future repatriation of such earnings, and therefore cannot quantify the tax liability that would be payable in the event all such foreign earnings are repatriated.
As of September 30, 2025, the current tax receivable, which was included in “Other receivables, net” on our Consolidated Statements of Financial Condition, was $79 million, and the current tax payable, which was included in “Other payables,” was $5 million. As of September 30, 2024, the current tax receivable was $28 million, and there was no current tax payable.
Uncertain tax positions
We recognize the accrual of interest and penalties related to income tax matters in “Interest expense” and “Other” expense, respectively. As of September 30, 2025 and 2024, accrued interest and penalties were $9 million and $14 million, respectively.
The following table presents the aggregate changes in the balances for uncertain tax positions.
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| | Year ended September 30, |
| $ in millions | | 2025 | | 2024 | | 2023 |
| Uncertain tax positions beginning of year | | $ | 48 | | | $ | 41 | | | $ | 43 | |
| Increases for tax positions related to the current year | | 15 | | | 6 | | | 5 | |
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Increases for tax positions related to prior years | | 6 | | | 9 | | | 4 | |
| Decreases for tax positions related to prior years | | — | | | (2) | | | (2) | |
Decreases due to statute of limitations expirations | | (16) | | | (6) | | | (8) | |
| Decreases related to settlements | | (6) | | | — | | | (1) | |
| Uncertain tax positions end of year | | $ | 47 | | | $ | 48 | | | $ | 41 | |
The total amount of uncertain tax positions that, if recognized, would impact the effective tax rate (the items included in the preceding table after considering the federal tax benefit associated with any state tax provisions) was $41 million at both September 30, 2025 and 2024, and $35 million at September 30, 2023. We anticipate that the uncertain tax position liability balance will decrease by approximately $11 million over the next 12 months due to expiration of statutes of limitations of federal and state tax returns.
RJF and its domestic subsidiaries are included in the consolidated income tax returns of RJF in the U.S. federal jurisdiction and various consolidated states. Our subsidiaries also file separate income tax returns in various state, local, and foreign jurisdictions. We are no longer subject to U.S. federal income tax examinations by tax authorities for fiscal years prior to fiscal 2022. With limited exceptions, we are no longer subject to income tax examinations by tax authorities for foreign jurisdictions for fiscal years prior to fiscal 2022 and state and local jurisdictions for fiscal years prior to fiscal 2021. Certain state and local and foreign tax returns are currently under various stages of audit and appeals processes.