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OCC Bulletin 2018-2 | January 18, 2018

Tax Reform: Interagency Statement on Accounting and Reporting Implications of the New Tax Law


Chief Executive Officers of All National Banks, Federal Savings Associations, and Federal Branches and Agencies of Foreign Banks; Department and Division Heads; All Examining Personnel; and Other Interested Parties


The Office of the Comptroller of the Currency (OCC), the Board of Governors of the Federal Reserve System, and the Federal Deposit Insurance Corporation today issued an interagency statement for supervised financial institutions on accounting and reporting implications of the new tax law1 and certain related matters. Changes required as a result of the new law, which was enacted on December 22, 2017, are relevant to December 31, 2017, financial statements and regulatory reports.

Note for Community Banks

This guidance applies to all OCC-supervised institutions.


The Financial Accounting Standards Board Accounting Standards Codification Topic 740, “Income Taxes,” requires that the effect of changes in tax laws or rates be recognized in the period in which the legislation is enacted. As the new tax law was enacted before December 31, 2017, institutions must record the effects of the new tax law in their December 31, 2017, regulatory reports. This guidance does not represent new rules or regulations, but instead clarifies

  • that changes in deferred tax assets and deferred tax liabilities resulting from the lower corporate income tax rate, and other applicable provisions of the new tax law, should be reflected in an institution’s income tax expense in the period of enactment.
  • how to resolve the disproportionate tax effects in accumulated other comprehensive income as a result of the remeasurement of deferred tax assets and liabilities.
  • the impact of the new tax law on regulatory capital.

Further Information

For more information or assistance, contact Sydney Menefee, Deputy Chief Accountant, or Rachel Binder, Professional Accounting Fellow, Office of the Chief Accountant, at (202) 649-6280.


Grace E. Dailey
Senior Deputy Comptroller for Bank Supervision Policy
and Chief National Bank Examiner

Related Link


1 The new tax law is “An Act to provide for reconciliation pursuant to titles II and V of the concurrent resolution on the budget for fiscal year 2018,” Pub. L. No. 115-97 (originally introduced as the Tax Cuts and Jobs Act).