On January 15, the IIB submitted a comment letter to the Internal Revenue Service (IRS) regarding the proposed regulations implementing the corporate alternative minimum tax (CAMT). The IIB reiterated significant concerns raised in the Institute’s previous comment letter that are not addressed by the proposed regulations, particularly around the “top-down” approach to determination of adjusted financial statement income for the U.S. operations of international banks, which could require use of a non-GAAP financial statement. The IIB again urged the IRS to clearly permit a “bottom-up” approach for the U.S. operations of international banks, utilizing financial statements prepared in accordance with U.S. GAAP. This would implement CAMT consistent with its purpose while minimizing compliance and examination burdens on both the IRS and taxpayers.

On December 9, 2024, the IIB submitted a comment letter to the Federal Reserve Board concerning its request for information on discount window operations. The IIB provided 10 recommendations to modernize the discount window to enhance functionality for the U.S. operations of international banks, including permitting submission of discount window access documents with electronic signatures or by electronic portal, reducing the operational burdens associated with pledging loans, and simplifying the process of pledging loans with foreign obligors.

On November 27, 2024, the IIB and Bank Policy Institute submitted a joint comment letter to the Federal Reserve Board on revisions to the Financial Statements for Holding Companies (FR Y-9C) and Capital Assessments and Stress Testing Reports (FR Y-14A). The associations recommended several clarifications and technical changes to increase consistency among reporting forms.