NOTE 18
 Income Taxes
The components of income before income taxes and income tax expense (benefit) were as follows:
Year Ended December 31 (Dollars in Millions)202520242023
Income before income taxes
U.S.$9,330 $7,786 $6,738 
Foreign187 123 127 
Total$9,517 $7,909 $6,865 
Income tax expense (benefit)
Current tax expense (benefit)
U.S. Federal$1,183 $1,252 $1,418 
U.S. State and local394 279 482 
Foreign36 20 16 
     Total current tax expense (benefit)1,613 1,551 1,916 
Deferred tax expense (benefit)
U.S. Federal209 (5)(342)
U.S. State and local99 35 (183)
Foreign— (1)16 
     Total deferred tax expense (benefit)308 29 (509)
Total income tax expense (benefit)
U.S. Federal1,392 1,247 1,076 
U.S. State and local493 314 299 
Foreign36 19 32 
     Total income tax expense (benefit)$1,921 $1,580 $1,407 
A reconciliation of expected income tax expense at the U.S. federal statutory rate of 21 percent to the Company’s applicable income tax expense follows:
Year Ended December 31 (Dollars in Millions)202520242023
AmountPercent AmountPercent AmountPercent
Tax at U.S. Federal statutory tax rate$1,999 21.0 %$1,661 21.0 %$1,442 21.0 %
    State income and local taxes, net of U.S. federal tax benefit(a)
446 4.7 320 4.0 266 3.9 
Foreign tax effects— — — .1 
Effect of cross-border tax laws11 .1 .1 (3)— 
Tax credits
   Renewable energy(378)(4.0)(230)(2.9)(119)(1.7)
   Other(139)(1.5)(119)(1.5)(106)(1.5)
Changes in valuation allowances33 .3 — — — — 
Nontaxable or nondeductible items
   Tax-exempt income(151)(1.6)(144)(1.8)(142)(2.1)
   Nondeductible legal and regulatory expenses46 .5 57 .7 76 1.1 
   Other32 .3 35 .4 34 .5 
Changes in unrecognized tax benefits21 .2 (65)(.8)(52)(.8)
Other adjustments(1)— 59 .7 .1 
   Applicable income taxes$1,921 20.2 %$1,580 20.0 %$1,407 20.5 %
(a)The majority of this category (greater than 50 percent) consists of California state taxes, California and Minnesota state taxes and California, Minnesota and New York state taxes for 2025, 2024 and 2023, respectively.
The components of cash paid for income taxes were:
Year Ended December 31 (Dollars in Millions)202520242023
U.S. Federal$338 $355 $517 
U.S. State and Local
   California120 85 44 
   New York*28 *
   Other50 15 64 
     Total U.S. State and local170 128 108 
Foreign36 16 20 
Total cash paid for income taxes$544 $499 $645 
* The amount of cash paid for income taxes was less than 5 percent of total cash paid for income taxes for all jurisdictions during the period.

The tax effects of fair value adjustments on securities available-for-sale, derivative instruments in cash flow hedges, foreign currency translation adjustments, and pension and post-retirement plans are recorded directly to shareholders’ equity as part of other comprehensive income (loss).
In preparing its tax returns, the Company is required to interpret complex tax laws and regulations and utilize income and cost allocation methods to determine its taxable income. On an ongoing basis, the Company is subject to examinations by U.S. federal, state, local and foreign taxing authorities that may give rise to differing
interpretations of these complex laws, regulations and methods. Due to the nature of the examination process, it generally takes years before these examinations are completed and matters are resolved. U.S. federal tax examinations for all years ending through December 31, 2020 are completed and resolved. The Company’s tax returns for the years ended December 31, 2021 through December 31, 2022 are under examination by the Internal Revenue Service. The years open to examination by foreign, state and local government authorities vary by jurisdiction.
A reconciliation of the changes in the U.S. federal, state and foreign uncertain tax position balances are summarized as follows:
Year Ended December 31 (Dollars in Millions)202520242023
Balance at beginning of period$256 $350 $513 
Additions for tax positions taken in prior years32 141 
Additions for tax positions taken in the current year
Exam resolutions(3)(131)(302)
Statute expirations(1)(1)(5)
Balance at end of period$267 $256 $350 
The total amount of uncertain tax positions that, if recognized, would impact the effective income tax rate as of December 31, 2025, 2024 and 2023, were $215 million, $206 million and $276 million, respectively. The Company classifies interest and penalties related to uncertain tax positions as a component of income tax expense. At December 31, 2025, the Company’s uncertain tax position balance included $39 million of accrued interest and penalties. During the years ended December 31, 2025,
2024 and 2023 the Company recorded approximately $12 million, $(13) million and $(11) million, respectively, in interest and penalties on uncertain tax positions.
Deferred income tax assets and liabilities reflect the tax effect of estimated temporary differences between the carrying amounts of assets and liabilities for financial reporting purposes and the amounts used for the same items for income tax reporting purposes.
The significant components of the Company’s net deferred tax asset (liability) follows:
At December 31 (Dollars in Millions)20252024
Deferred Tax Assets  
U.S. federal, state and foreign net operating loss, credit carryforwards and other carryforwards$2,521 $2,772 
Securities available-for-sale and financial instruments2,168 3,129 
Allowance for credit losses2,068 2,086 
Accrued expenses638 767 
Loans622 869 
Obligation for operating leases349 341 
Partnerships and other investment assets321 264 
Stock compensation84 89 
Fixed assets38 — 
Other deferred tax assets, net331 383 
Gross deferred tax assets9,140 10,700 
Deferred Tax Liabilities
Goodwill and other intangible assets(1,272)(1,362)
Leasing activities(1,087)(1,273)
Mortgage servicing rights(760)(789)
Right of use operating leases(311)(297)
Pension and postretirement benefits(241)(184)
Fixed assets— (28)
Other deferred tax liabilities, net(48)(125)
Gross deferred tax liabilities(3,719)(4,058)
Valuation allowance(432)(389)
Net Deferred Tax Asset$4,989 $6,253 
The Company has approximately $142 million of deferred tax assets related to U.S. federal, state and foreign net operating loss carryforwards which expire at various times beginning in 2026. A substantial portion of these carryforwards relate to state-only net operating losses, for which the related deferred tax asset is subject to a full valuation allowance as the carryforwards are not expected to be realized within the carryforward period.
In addition, the Company has $1.3 billion of U.S. federal and state credit carryforwards which expire at various times through 2045. Certain of these carryforwards are subject to a valuation allowance as management believes that it is more likely than not that the credits will not be utilized within the carryforward period.
Management has determined it is more likely than not the other net deferred tax assets could be realized through carry back to taxable income in prior years, future reversals of existing taxable temporary differences and future taxable income.

At December 31, 2025, retained earnings included approximately $102 million of base year reserves of acquired thrift institutions, for which no deferred U.S. federal income tax liability has been recognized. These base year reserves would be recaptured if certain subsidiaries of the Company cease to qualify as a bank for U.S. federal income tax purposes. The base year reserves also remain subject to income tax penalty provisions that, in general, require recapture upon certain stock redemptions of, and excess distributions to, stockholders.

Historical Timeline

Fiscal YearFiled
2025Feb 23, 2026Showing above
2024Feb 21, 2025
2023Feb 20, 2024
2022Feb 27, 2023
2021Feb 22, 2022
2020Feb 23, 2021
2019Feb 20, 2020
2018Feb 22, 2019
2017Feb 22, 2018
2016Feb 23, 2017
2015Feb 25, 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.