(1)
In order to
determine a financial institution's total Ohio equity capital for tax years
beginning on or after January 1, 2020, a financial institution's total equity
capital, to which the apportionment factor is applied, is limited to fourteen
per cent of the financial institution's total assets. For purposes of this
limitation, "total assets" are the financial institution's total consolidated
assets reported as of the end of the taxable year as follows, subject to audit
and adjustment by the tax commissioner:
(a)
For a reporting
person that is a bank holding company and that files a FR Y-9C, the total
consolidated assets of the financial institution as reported on the FR Y-9C,
including the total assets of all entities consolidated for purposes of filing
the FR Y-9C;
(b)
For a reporting person that is a bank holding company
and that files a FR Y-9SP, the total consolidated assets of the financial
institution as reported on the FR Y-9SP, including the total assets of all
entities that would be consolidated for purposes of filing a FR Y-9C if the
bank holding company were required to file a FR Y-9C. The total consolidated
assets as reported on schedule SC-M of the FR Y-9SP may be used if the total
consolidated assets as reported reflect the actual amount of total consolidated
assets of the financial institution;
(c)
For a reporting
person that is a bank organization and that files a call report, the total
consolidated assets of the financial institution as reported on the call
report, including the total assets of all entities consolidated for purposes of
filing the call report;
(d)
For all other reporting persons, the total consolidated
assets of the financial institution in accordance with generally accepted
accounting principles. If the financial institution consists of a single
entity, the total consolidated assets will only comprise of that entity's total
assets.
(2)
Examples of the total equity capital limitation
applicable to tax years beginning on or after January 1, 2020:
(a)
Reporting person,
A, is a large bank holding company that files a FR Y-9C. A's FR Y-9C for the
period ending December 31, 2019 showed total equity capital of nine hundred
fifty million dollars and total consolidated assets of ten billion five hundred
million dollars. To determine whether the limit on total equity capital will
reduce the amount apportioned to Ohio for purposes of the FIT, A will multiply
its total consolidated assets by fourteen per cent and then compare that amount
to its total equity capital: 0.14 x $10,500,000,000 = $1,470,000,000. Because
fourteen per cent of A's total consolidated assets (one billion four hundred
seventy million dollars) is greater than A's total equity capital (nine hundred
fifty million dollars), the limitation on total equity capital will not impact
A for tax year 2020. A will apply its apportionment factor to its total equity
capital of $950,000,000 to determine its total Ohio equity
capital.
(b)
Reporting person, B, is a small bank holding company
that files a FR Y-9SP. B's FR Y-9SP for the period ending December 31, 2019
showed total equity capital of forty millon dollars and total consolidated
assets of two hundred fifty million dollars. To determine whether the limit on
total equity capital will reduce the amount apportioned to Ohio for purposes of
the FIT, B will multiply its total consolidated assets by fourteen per cent and
then compare that amount to its total equity capital: 0.14 x $250,000,000 =
$35,000,000. Because fourteen per cent of B's total consolidated assets
(thirty-five million dollars) is less than B's total equity capital (forty
million dollars), B's total equity capital for purposes of determining the FIT
for tax year 2020 will be reduced to equal fourteen per cent of its total
consolidated assets, or thirty-five million dollars. B will apply its
apportionment factor to thirty-five million dollars to determine its total Ohio
equity capital for tax year 2020.