An intercompany tax allowance agreement is a contractual agreement on the calculation of income tax (current and latent), payment of income tax and refunds to an institution when it has a loss of tax. A holding company and its subsidiary (s) are invited to enter into a comprehensive and written tax allowance agreement, adapted to its particular circumstances. The agreement should be approved by the relevant boards of directors and regularly reviewed and updated by legal advisors. Federal banks expect institutions and holding companies to fully implement the addendum as soon as possible, which agencies should not expect later than October 31, 2014. You can read the text of the addendum by clicking here. This agreement will be concluded on April 21, 2015 with: SOUTHERN MISSOURI BANCORP, INC. (“SMBC”), missouri Corporation, and Southern Bank (the bank), a chartered trust company in Missouri with banking powers. The parties are members (“members”) of an affiliated group (“Linked Group”) within the meaning of Section 1504 of the Internal Income Code (“Code”) and submit a consolidated tax return for federal tax purposes. SMBC is the joint parent company of the linked group. The parties intend to plan the distribution of tax debt among members and to provide for the repayment of members whose losses or tax credits reduce consolidated taxable income. References to “regulations” must be referred to treasury rules.
For “tax liabilities,” these are current tax liabilities, not latent liabilities; However, the bank does not transfer any of its deferred tax debts to SMBC through cash payments or any other means, excluding it from the agreement reached on April 1, 2013 by and between Bancshares, Allegiance, Inc., a Texas limited company and a registered holding company (hereafter referred to as “parent company”), and Allegiance Bank Texas, a Texas bank company (hereafter referred to as a subsidiary of the bank). This tax-granting agreement (“convention”) takes place on the effective date, as defined below, from and between Lehman Brothers Holdings Inc., a Delaware company (“LBHI”), and Woodlands Commercial Bank (f/k/a Lehman Brothers Commercial Bank), an industrial bank in Utah and an indirect subsidiary of LBHI (“Woodlands”) and its operating subsidiaries, if there is (the “bank”) (above referred to as “parties” or “parties” in the banking sector).