PLR 200227032: Taxpayer gets extra time for dual consolidated loss agreements

View official IRS release (PDF)

Plain-English summary

A taxpayer missed the deadline to file agreements concerning dual consolidated losses of the entities and tax years listed in an attached schedule. An employee responsible for the filings was a qualified tax professional, and the IRS found the omission inadvertent despite the taxpayer's reliance on that employee. The IRS concluded that the taxpayer acted reasonably and in good faith and that an extension would not prejudice the government. It granted 30 days from the letter date to file the required agreements. The ruling did not confirm the schedule's accuracy or decide whether the taxpayer was otherwise eligible to file the agreements.

Ruling snapshot

• Question: Can the taxpayer file the listed dual consolidated loss agreements after their deadline?
• Outcome: Approved, with a 30-day extension from the letter date
• Key authorities: Treas. Reg. §§ 1.1503-2(g)(2), 301.9100-1(c), 301.9100-3(a)

Full text (IRS public release)

Internal Revenue Service
Department of the Treasury

Number: 200227032
Washington, DC 20224
Release Date: 7/5/2002
Index Number: 9100.22-00
Person to Contact:
1503.04-04
Telephone Number:

Refer Reply To:
CC:INTL:PLR-143044-01
Date:
April 5, 2002

LEGEND

Taxpayer
=

Individual A
=

Dear
:

This replies to a letter dated August 8, 2001, in which Taxpayer requests an extension of time under Treas. Reg. § 301.9100-3 to file agreements required under § 1.1503- 2(g)(2)(iv)(B)(2)(iii) with respect to the dual consolidated losses of the entities and the respective tax years listed on Schedule A, which is attached and is part of this ruling letter. The information submitted for consideration is substantially as set forth below.

The ruling contained in this letter is predicated upon facts and representations submitted by the taxpayer and accompanied by a penalty of perjury statement executed by an appropriate party. This office has not verified any of the material submitted in support of the request for a ruling. Verification of the factual information, representations, and other data may be required as a part of the audit process.

Individual A is employed by Taxpayer as a tax professional and was given the responsibility for complying with the requirements of § 1.1503-2(g)(2)(iv)(B)(2)(iii) for the entities and tax years at issue. The affidavit of Individual A and the facts submitted describe in detail the circumstances that led to the failure to file the agreements. The affidavits and facts show that the failure to file the agreements was inadvertent and occurred notwithstanding Taxpayer’s reliance on Individual A as a qualified tax professional.
2

In re: PLR-143044-01

Treas. Reg. § 301.9100 -1(b) defines a regulatory election as an election whose due date is prescribed by a regulation, a revenue ruling, revenue procedure, notice, or announcement.

Treas. Reg. § 301.9100-1(c) provides that the Commissioner has discretion to grant a taxpayer a reasonable extension of time to make a regulatory election under the rules set forth in § 301.9100-3 and under all subtitles of the Internal Revenue Code except subtitles E, G, H, and I.

Treas. Reg. § 301.9100-3(a) provides that requests for relief subject to this section will be granted when the taxpayer provides the evidence (including affidavits described in
§ 301.9100-3(e)) to establish to the satisfaction of the Commissioner that the taxpayer acted reasonably and in good faith, and the grant of relief will not prejudice the interests of the Government.

In the present situation, § 1.1503-2(g)(2)(i) fixes the time to file an election and agreement. Therefore, the Commissioner has discretionary authority under
§ 301.9100–1(c) to grant Taxpayer an extension of time, provided that Taxpayer satisfies the standards set forth in § 301.9100-3(a).

Based on the facts and circumstances of this case, we conclude that Taxpayer satisfies § 301.9100-3(a). Accordingly, Taxpayer is granted an extension of time until 30 days from the date of this ruling letter to file agreements required under § 1.1503- 2(g)(2)(iv)(B)(2)(iii) with respect to the dual consolidated losses of the entities and the respective tax years listed on Schedule A, which is attached and is part of this ruling letter.

Nothing in this ruling letter is to be construed as confirming the accuracy of the information you have furnished and this is specifically the case regarding the information listed on Schedule A. As previously stated, verification of that information may be required as part of the audit process.

As provided in § 301.9100-1(a), the granting of an extension of time is not a determination that Taxpayer is otherwise eligible to file the agreements.

This ruling is directed only to the taxpayer who requested it. I.R.C. § 6110(k)(3) provides that it may not be used or cited as precedent.

A copy of this ruling letter should be associated with the agreements.

No ruling has been requested, and none is expressed, as to the application of any other section of the Code or regulations to the facts presented.
3

In re: PLR-143044-01

Pursuant to a power of attorney on file in this office, a copy of this ruling letter is being furnished to Taxpayer.

Sincerely,

/s/ Allen Goldstein
Allen Goldstein
Reviewer
Office of the Associate Chief Counsel (International)

Attachment
Schedule A
4

In re: PLR-143044-01

Schedule A

I.

A.

Tax Year
Amount
1994
1995
16,098,364
1996
2,678,312
1997
5,037,661
1998 (1/1/98-9/30/98)
599,955

2. BANTSA-Belgium
Bank of America NT&SA, Antwerp and Brussels Branches, Banking
Foreign Branch Separate Unit and Dual Resident Corporation

Tax Year
Amount
1992
2,559,092
1995
638,694
1996
16,190
1997
1,999,964

.
BANTSA-Cayman Islands
Bank of America NT&SA, Grand Cayman Branch, Banking 5

In re: PLR-143044-01

Foreign Branch Separate Unit and Dual Resident Corporation

Tax Year
Amount
1992
6,373
1993
5,827
1994
6,735
1995
6,575
1996
8,049
1997
6,937
1998 (1/1/98-9/30/98)
2,417

4. BANTSA-China
Bank of America NT&SA, Guangzhou, Beijing and Shanghai Branches, Banking
Foreign Branch Separate Unit and Dual Resident Corporation

Tax Year
Amount
1992
94,589
1993
128,469
1994
386,075
1997
588,365
1998 (1/1/98-9/30/98)
349,070

5. BANTSA-Ecuador
Bank of America NT&SA, Quito Branch, Banking Foreign Branch Separate Unit and Dual Resident Corporation

Tax Year
Amount
1992
758,593
1993
410,259

6. BANTSA-Egypt
Bank of America NT&SA, Cairo Branch, Banking Foreign Branch Separate Unit and Dual Resident Corporation

Tax Year
Amount
6

In re: PLR-143044-01

1994
2,431,573
1995
514,026
1996
288,858
1997
27,714
1998 (1/1/98-9/30/98)
24,239

7. BANTSA-France
Bank of America NT&SA, Paris Branch, Banking Foreign Branch Separate Unit and Dual Resident Corporation

Tax Year
Amount
1991
10,468,776
1992
11,076,685
1994
7,289,301
1995
7,779,668
1996
7,913,948
1997
5,344,942
1998 (1/1/98-9/30/98)
689,966

8. BANTSA-Germany
Bank of America NT&SA, Frankfurt Branch, Banking Foreign Branch Separate Unit and Dual Resident Corporation

Tax Year
Amount
1992
1,737,706

9. BANTSA-Hong Kong
Bank of America NT&SA, Global Payment Services Branch, Banking
Foreign Branch Separate Unit and Dual Resident Corporation

Tax Year
Amount
1992
1,698,023
1993
1,913,065

10. BANTSA-India
Bank of America NT&SA, Mumbai, Chennai and New Delhi Branches, Banking
Foreign Branch Separate Unit and Dual Resident Corporation

Tax Year
Amount
1995
7,441,401
7

In re: PLR-143044-01

11. BANTSA-Ireland
Bank of America NT&SA, Dublin Branch, Banking Foreign Branch Separate Unit and Dual Resident Corporation

Tax Year
Amount
1992
3,823,825
1994
2,774,982

12. BANTSA-Italy
Bank of America NT&SA, Milan Branch, Banking Foreign Branch Separate Unit and Dual Resident Corporation

Tax Year
Amount
1998 (1/1/98-9/30/98) 5,032,869

13. BANTSA-Japan
Bank of America NT&SA, Osaka, Tokyo and Financial Engineering Risk Management Branches, Banking
Foreign Branch Separate Unit and Dual Resident Corporation

Tax Year
Amount
1992
8,065,169
1993
15,627,562
1994
32,836,802
1996
14,836
1997
35,509,233
1998 (1/1/98-9/30/98)
8,446,701

14. BANTSA-Malaysia
Bank of America NT&SA, Labuan Branch, Banking Foreign Branch Separate Unit and Dual Resident Corporation

Tax Year
Amount
1994
51,419

15. BANTSA-Netherlands
Bank of America NT&SA, Amsterdam Branch, Banking Foreign Branch Separate Unit and Dual Resident Corporation 8

In re: PLR-143044-01

Tax Year
Amount
1992
1,188,401
1994
2,625,113

16. BANTSA-Panama
Bank of America NT&SA, Panama Branch, Banking Foreign Branch Separate Unit and Dual Resident Corporation

Tax Year
Amount
1993
30,739

17. BANTSA-Peru
Bank of America NT&SA, Lima Branch, Banking Foreign Branch Separate Unit and Dual Resident Corporation

Tax Year
Amount
1992
308,173

18. BANTSA-Philippines
Bank of America NT&SA, Manila Branch, Banking Foreign Branch Separate Unit and Dual Resident Corporation

Tax Year
Amount
1993
1,308,591

19. BANTSA-Singapore
Bank of America NT&SA, Singapore and Orchard Branches, Banking
Foreign Branch Separate Unit and Dual Resident Corporation

Tax Year
Amount
1993
6,472,379

20. BANTSA-Switzerland
Bank of America NT&SA, Geneva and Zurich Branches, Banking Foreign Branch Separate Unit and Dual Resident Corporation

Tax Year
Amount
1992
2,993,570
9

In re: PLR-143044-01

1994
1,388,102
1995
2,103,596
1996
545,991

21. BANTSA-Taiwan
Bank of America NT&SA, Taipei Offshore Banking Branch, Banking Foreign Branch Separate Unit and Dual Resident Corporation

Tax Year
Amount
1992
3,496,805
1993
13,662,328
1994
10,342,508

22. BANTSA-Taiwan
Bank of America NT&SA, Taiwan Branch, Banking Foreign Branch Separate Unit and Dual Resident Corporation

Tax Year
Amount
1993
3,729,392
1996
2,178,910

23. BANTSA-United Arab Emirates
Bank of America NT&SA, Dubai Branch, Banking Foreign Branch Separate Unit and Dual Resident Corporation

Tax Year
Amount
1995
165,772
1996
531,657
1997
624,383

24. BANTSA-United Kingdom
Bank of America NT&SA, London Branch, Banking Foreign Branch Separate Unit and Dual Resident Corporation

Tax Year
Amount
1992
24,591,000
1997
1,001,217
1998 (1/1/98-9/30/98) 316,851,469 10

In re: PLR-143044-01

25. BANTSA-Vietnam
Bank of America NT&SA, Hanoi Branch, Banking Foreign Branch Separate Unit and Dual Resident Corporation

Tax Year
Amount
1995
1,211,611
1996
956,028

B. SPLC

1. SPLC-Japan
Security Pacific Leasing Corporation, Tokyo Branch, Leasing Foreign Branch Separate Unit and Dual Resident Corporation

Tax Year
Amount
1992 (4/23/92 – 12/31/92) 301,912
1993
460,617
1995
5,976

2. SPLC-Singapore
Security Pacific Leasing Corporation, Singapore Branch, Leasing Foreign Branch Separate Unit and Dual Resident Corporation

Tax Year
Amount
1992 (4/23/92 – 12/31/92) 198,534
1993
2,884

3. SPLC-United Kingdom
Security Pacific Leasing Corporation, United Kingdom Branch, Leasing
Foreign Branch Separate Unit and Dual Resident Corporation

Tax Year
Amount
1992 (4/23/92 – 12/31/92) 173,480
1993
432,547

C. SPEF

1. SPEF-Belgium
11

In re: PLR-143044-01

Security Pacific EuroFinance, Inc., Belgium Branch, Leasing Foreign Branch Separate Unit and Dual Resident Corporation

Tax Year
Amount
1995
3,261

2. SPEF-France
Security Pacific EuroFinance, Inc., France Branch, Leasing Foreign Branch Separate Unit and Dual Resident Corporation

Tax Year
Amount
1992 (4/23/92 – 12/31/92)
250
1993
3,044,809
1995
3,476,071
1996
330,000
1997
331,000
1998 (1/1/98-9/30/98)
220,000

3. SPEF-Germany
Security Pacific EuroFinance, Inc., Munich Branch, Leasing Foreign Branch Separate Unit and Dual Resident Corporation

Tax Year
Amount
1992 (4/23/92 – 12/31/92) 575,125
1993
1,786,612
1994
88,950
1995
7,543

4. SPEF-Italy
Security Pacific EuroFinance, Inc., Italy Branch, Leasing Foreign Branch Separate Unit and Dual Resident Corporation

Tax Year
Amount
1992 (4/23/92 – 12/31/92) 31,776
1993
380,335
1994
2,150

5. SPEF-Netherlands
Security Pacific EuroFinance, Inc., Netherlands Branch, Leasing Foreign Branch Separate Unit and Dual Resident Corporation 12

In re: PLR-143044-01

Tax Year
Amount
1993
100
1995
39,448

6. SPEF-United Kingdom
Security Pacific EuroFinance, Inc., United Kingdom Branch, Leasing
Foreign Branch Separate Unit and Dual Resident Corporation

Tax Year
Amount
1993
78,091,087

D. BAI
1. BAI-Argentina
Bank of America Illinois, Buenos Aires Branch, Banking Foreign Branch Separate Unit and Dual Resident Corporation

Tax Year
Amount
1994 (9/1/94 – 12/31/94) 6,629,285
1995
322,513

2. BAI-Bahamas
Bank of America Illinois, Nassau Branch, Banking Foreign Branch Separate Unit and Dual Resident Corporation

Tax Year
Amount
1994 (9/1/94 – 12/31/94) 7,167,583
1995
14,849,050
1996
4,799,231

3. BAI-Chile
Bank of America Illinois, Santiago Branch, Banking Foreign Branch Separate Unit and Dual Resident Corporation

Tax Year
Amount
1994 (9/1/94 – 12/31/94) 275,726
1995
1,007,487
13

In re: PLR-143044-01

4. BAI-Japan
Bank of America Illinois, Tokyo Branch, Banking Foreign Branch Separate Unit and Dual Resident Corporation

Tax Year
Amount
1994 (9/1/94 – 12/31/94) 7,559,385
1995
2,387,155

5. BAI-United Kingdom
Bank of America Illinois, London Branch, Banking Foreign Branch Separate Unit and Dual Resident Corporation

Tax Year
Amount
1995
9,104,335
1996
572,861

E. AHL
Appold Holdings Limited, London Branch, Leasing Foreign Branch Separate Unit and Dual Resident Corporation

Tax Year
Amount
1992 (4/23/92 – 12/31/92) 354,099,581
1993
30,542,144
1994
20,689,262
1995
5,202,595

F. BACAN
Bank of America Canada, Canada, Banking
Foreign Branch Separate Unit and Dual Resident Corporation

Tax Year
Amount
1987
1,273,879
1991
37,449,672
1992
19,433,278
1993
15,571,423
14

In re: PLR-143044-01

G. CIDM
Continental Illinois de Mexico, Mexico, Banking Foreign Branch Separate Unit and Dual Resident Corporation

Tax Year
Amount
1994 (9/1/94 – 12/31/94)
7,965,145
1995
4,368,070

BA Futures, Incorporated (“BAFI”)
BA Futures, Paris Branch, Futures Trading

Note: BAFI was included in previous dual consolidated loss filings based on the misunderstanding that BA Futures S.A.
(BASA) was a partnership.

I. BACSC
Bank of America Canada Securities Corporation, Canada, Securities Trading
Foreign Branch Separate Unit and Dual Resident Corporation

Tax Year
Amount
1991
2,331
1992
1,843

J. BACAN Leasing
Bank of America Canada Leasing Corporation, Canada, Leasing
Foreign Branch Separate Unit and Dual Resident Corporation

Tax Year
Amount
1988
155,384

K. SPBC
Security Pacific Bank Canada, Canada, Banking Foreign Branch Separate Unit and Dual Resident Corporation

Tax Year
Amount
1992 (4/23/92 – 12/31/92) 6,076,623 15

In re: PLR-143044-01

L. Arrendadora
Arrendadora, Mexico, Leasing
Foreign Branch Separate Unit and Dual Resident Corporation

Tax Year
Amount
1997
1,704,3651
1998 (1/1/98-9/30/98)
942,398

M. BAMSA
Bank of America, Mexico, Banking
Foreign Branch Separate Unit and Dual Resident Corporation

Tax Year
Amount
1997
10,344,9222
1998 (1/1/98-9/30/98)
15,547,908

II. CBC DCLs

A. CBNA

1. CBNA-Argentina

1
Former BAC erroneously failed to report this amount in the election and agreement described in Treasury Regulation section 1.1503-2(g)(2) it filed with its 1997 return. This was corrected with an amended filing on November 13, 2000, pursuant to an extension of time that was granted by a private letter ruling from the IRS, dated October 12, 2000. See attached Schedule 1-A. 2 Former BAC erroneously failed to report this amount in the election and agreement described in Treasury Regulation section 1.1503-2(g)(2) it filed with its 1997 return. This was corrected with an amended filing on November 13, 2000, pursuant to an extension of time that was granted by a private letter ruling from the IRS, dated October 12, 2000. See attached Schedule 1-A.
16

In re: PLR-143044-01

Continental Bank, Buenos Aires Branch, Banking Foreign Branch Separate Unit and Dual Resident Corporation

Tax Year
Amount
1992
217,706
1994 (1/1/94 – 8/31/94) 6,687,118

2. CBNA-Bahamas
Continental Bank, Nassau Branch, Banking Foreign Branch Separate Unit and Dual Resident Corporation

Tax Year
Amount
1987
2,200,738
1991
2,792,044
1994 (1/1/94 – 8/31/94) 42,608,446

3. CBNA-Chile
Continental Bank, Santiago Branch, Banking Foreign Branch Separate Unit and Dual Resident Corporation

Tax Year
Amount
1992
686,640

4. CBNA-France
Continental Bank, Paris Branch, Banking
Foreign Branch Separate Unit and Dual Resident Corporation

Tax Year
Amount
1987
5,250,285
1988
12,207,716
1989
11,004,837
1990
9,219,311
1991
490,835

5. CBNA-Hong Kong
Continental Bank, Hong Kong Branch, Banking Foreign Branch Separate Unit and Dual Resident Corporation

Tax Year
Amount
1988
273,493
1989
3,527,914
17

In re: PLR-143044-01

1990
3,503,490
1991
479,767

6. CBNA-Italy
Continental Bank, Milan Branch, Banking
Foreign Branch Separate Unit and Dual Resident Corporation

Tax Year
Amount
1987
2,751,493
1988
4,750,614
1992
4,122,119

7. CBNA-Japan
Continental Bank, Tokyo Branch, Banking
Foreign Branch Separate Unit and Dual Resident Corporation

Tax Year
Amount
1987
3,771,330
1988
15,981,066
1989
27,953,024
1990
22,435,164
1991
8,444,287
1992
2,350,373
1993
700,091
1994 (1/1/94 – 8/31/94) 2,056,208

8. CBNA-Singapore
Continental Bank, Singapore Branch, Banking Foreign Branch Separate Unit and Dual Resident Corporation

Tax Year
Amount
1987
2,854,249
1988
26,509,969
1989
665,427
1990
2,435,606
1991
2,190,568
18

In re: PLR-143044-01

9. CBNA-United Kingdom
Continental Bank, London Branch, Banking Foreign Branch Separate Unit and Dual Resident Corporation

Tax Year
Amount
1987
319,078
1988
29,467,508
1989
17,078,632
1990
64,666,620
1991
96,430,056
1992
45,314,379
1994 (1/1/94 – 8/31/94) 25,376,356

B. Options-Japan
Continental First Options, Tokyo Branch, Options Clearing Foreign Branch Separate Unit and Dual Resident Corporation

Tax Year
Amount
1989
580,809
1991
175,951

III. SPC DCLs

A. SPNB

1. SPNB-Germany
Security Pacific National Bank, Munich Branch, Banking Foreign Branch Separate Unit and Dual Resident Corporation

Tax Year
Amount
1988
922,057
1989
16,293,192
1990
9,036,131
1991
3,777,956
1992 (1/1/92 – 4/22/92)
2,882,664
19

In re: PLR-143044-01

2. SPNB-Hong Kong
Security Pacific National Bank, Hong Kong Branch, Banking Foreign Branch Separate Unit and Dual Resident Corporation

Tax Year
Amount
1987
303,342
1988
2,855,637
1989
1,071,975
1992 (1/1/92 – 4/22/92) 3,460,792

3. SPNB-United Kingdom
Security Pacific National Bank, London Branch, Banking Foreign Branch Separate Unit and Dual Resident Corporation

Tax Year
Amount
1989
34,589,919
1990
75,345,858
1991
181,553,496
1992 (1/1/92 – 4/22/92) 64,122,744

4. SPNB-Philippines
Security Pacific National Bank, Manila Branch, Banking Foreign Branch Separate Unit and Dual Resident Corporation

Tax Year
Amount
1990
301,758

5. SPNB-Bahamas
Security Pacific National Bank, Nassau Branch, Banking Foreign Branch Separate Unit and Dual Resident Corporation

Tax Year
Amount
1987
1,779,216
1989
1,261,372

6. SPNB-Taiwan
Security Pacific National Bank, Taiwan Branch, Banking Foreign Branch Separate Unit and Dual Resident Corporation 20

In re: PLR-143044-01

Tax Year
Amount
1992 (1/1/92 – 4/22/92)
27,100

7. SPNB-Japan
Security Pacific National Bank, Tokyo Branch, Banking Foreign Branch Separate Unit and Dual Resident Corporation

Tax Year
Amount
1987
1,684,044
1988
1,782,953
1991
21,894,102
1992 (1/1/92 – 4/22/92) 1,429,811

B. SPLC

1. SPLC-Hong Kong
Security Pacific Leasing Corporation, Hong Kong Branch, Leasing Foreign Branch Separate Unit and Dual Resident Corporation

Tax Year
Amount
1987
177,070
1988
154,804

2. SPLC-Japan
Security Pacific Leasing Corporation, Tokyo Branch, Leasing Foreign Branch Separate Unit and Dual Resident Corporation

Tax Year
Amount
1987
417,175
1990
435,428
1991
460,190
1992 (1/1/92 – 4/22/92)
97,277

3. SPLC-United Kingdom
Security Pacific Leasing Corporation, London Branch, Leasing Foreign Branch Separate Unit and Dual Resident Corporation

Tax Year
Amount
1988
171,217
21

In re: PLR-143044-01

1989
14,735
1990
188,806
1991
283,755
1992 (1/1/92 – 4/22/92)
56,658

4. SPLC-Singapore
Security Pacific Leasing Corporation, Singapore Branch, Leasing Foreign Branch Separate Unit and Dual Resident Corporation

Tax Year
Amount
1987
351,524
1988
56,908
1989
239,533
1990
62,736
1992 (1/1/92 – 4/22/92)
88,657

C. SPEF

1. SPEF-Germany
Security Pacific EuroFinance, Inc., Munich Branch, Leasing Foreign Branch Separate Unit and Dual Resident Corporation

Tax Year
Amount
1987
2,351,281
1988
2,042,219
1989
1,326,998
1991
4,525,828

2. SPEF-United Kingdom
Security Pacific EuroFinance, Inc., United Kingdom Branch, Leasing
Foreign Branch Separate Unit and Dual Resident Corporation

Tax Year
Amount
1992 (1/1/92 – 4/22/92) 732,015

3. SPEF-France
22

In re: PLR-143044-01

Security Pacific EuroFinance, Inc., France Branch, Leasing Foreign Branch Separate Unit and Dual Resident Corporation

Tax Year
Amount
1987
2,988
1989
304
1990
1,012
1991
244
1992 (1/1/92 – 4/22/92)
73

4. SPEF-Netherlands
Security Pacific EuroFinance, Inc., Netherlands Branch, Leasing Foreign Branch Separate Unit and Dual Resident Corporation

Tax Year
Amount
1991
304,663
1992 (1/1/92 – 4/22/92)
51,524

5. SPEF-Belgium
Security Pacific EuroFinance, Inc., Belgium Branch, Leasing Foreign Branch Separate Unit and Dual Resident Corporation

Tax Year
Amount
1987
508,457
1988
403,726
1989
762,604
1991
239,690
1992 (1/1/92 – 4/22/92)
30,237

6. SPEF-Italy
Security Pacific EuroFinance, Inc., Italy Branch, Leasing Foreign Branch Separate Unit and Dual Resident Corporation

Tax Year
Amount
1987
91,590
1988
75,343
1989
104,141
1990
80,851
1991
15,543

7. SPEF-United Kingdom
23

In re: PLR-143044-01

Security Pacific EuroFinance, Inc., United Kingdom Regional Management Branch, Leasing
Foreign Branch Separate Unit and Dual Resident Corporation

Tax Year
Amount3
1987
3,891,236
1988
4,061,235
1989
2,103,927
1990
21,676,772
1991
8,930,666
1992 (1/1/92 – 4/22/92)
993,253

D. SPBC
Security Pacific Bank Canada, Canada, Banking Foreign Branch Separate Unit and Dual Resident Corporation

Tax Year
Amount
1991
45,439,696
1992 (1/1/92 – 4/22/92)
39,233,166

E. SPHGEV-United Kingdom
Security Pacific Hoare Govett Equity Ventures, Ltd., United Kingdom Branch, Venture Capital
Foreign Branch Separate Unit and Dual Resident Corporation

Tax Year
Amount
1987
260,684
1988
122,735
1989
707,689

F. SPHGH-United Kingdom
Security Pacific Hoare Govett (Holdings) Ltd., London, Leasing
Foreign Branch Separate Unit and Dual Resident Corporation

3
24

In re: PLR-143044-01

Tax Year
Amount
1987
86,841,103
1988
8,574,311
1989
63,755,916

cc Internal Revenue Service
Attn: Industry Director, Financial Services & Healthcare (LM:FSH) 290 Broadway, 12th Floor
New York, NY 10007

cc: Bank of America Corporation
Corporate Tax Department
NC1-021-02-20
401 N. Tryon Street
Charlotte, NC 28255