For starters, the claim of a 38 billion dollar tax break is highly misleading as phrased. (At least with regards to actually saving Citi Bank that kind of money, which is clearly the impression conveyed by some of these articles.)
Well, it's not misleading at all. They're using the normal terminology for such a benefit, had they said a "38 billion dollar tax credit" I'd have to agree with you.
Now, I'd say it's not clear yet (to me anyway) how much a tax reduction this suspect ruling will give Citi (and other TARP banks).
Our corporate tax rate is 35%. (There are brackets, and the rate goes up to 38% in order to eliminate the lower brackets so that at about $18M we're looking at a flat 35% rate on all profit.) $38B x 35% = $13.3B for this one bank. But that would be maximum benefit, however I think it lower than that because I doubt all the $38B would hve been disallowed (if not for this ruling). But this calculation is a complex one (it's in Internal revenue Section 382). Until I see a tax CPA's calculation, or if it's the IRS ruling (which I haven't yet found) I'll take any estimate from a journalist or economist with a great big bucket of salt.
We're talking about several billion dollars in actual potential savings, but when you look how this actually works with the US Government actually owning Citibank shares right now,
this probably is actually a break even move for taxpayers overall if not actually saving taxpayer money.
http://marketplace.publicradio.org/display/web/2009/12/16/pm-citi-tax/
Basically if the stock price of Citigroup drops enough as a result of this ruling, it actually could be a greater cost to the government than the potential ruling since the US government is going to be selling it Citigroup shares soon.
I disagree with the bolded sentence, and I think we're hearing some BS from the gov etc.
Explain the difference between these two senarios (other than structure, isn't the
substance the same?)
1. Bank pays $10 billion in tax. Government gives bank $10 billion in more aid so it can pay off the TARP loan. That $10 B is taxpayer money, it'll increase the deficit that we taxpayer must eventually pay off. The government has given $10B of taxpayer money so bank can payoff $10B in TARP. Net effect to us taxpayers is ZERO ($10B in TARP received from bank less $10B in tax money given to bank = zero)
2. Government issues ruling that bank doesn't owe $10B in taxes. Bank just keeps money and uses it to pay back TARP funds. Same net effect as #1 above.
Numbers 1 and 2 acheive the exact same thing. However, in number 1 it's obvious we're giving the bank $10B to pay us back the $10B they owe us, meaning they haven't paid back a damn thing. This would be politically unpopular and seen for what it is, another 'bailout' to banks, and no 'real' payback of TARP funds.
We're getting snookered people.
BTW: It's questionable that this has an effect on the banks stock. At that level, stock is valued using a forumla called EBITDA. EBITDA means "earnings before interest,
taxes, depreciation and amortization". Notice how taxes are NOT included in the stock valuation?
But let's forget about that for a moment. Let's forget about #1 and #2 above. If the US gov 'gives' $10B to the bank making it's stock value go up, we're netting zero (at best, likely we're losing). If the $10B translates into $10B more value in the gov's stock we're at zero ($10B 'extra' received in sale of preferred stock less $10B given away = zero).
However, it's likely we're coming not even, but at a loss. If the $10B translated into an increase of $10 for the bank's worth we got a problem. You see the gov doesn't own 100% of the bank. If the gov owned 25% (it's actually less because IIRC they own about 25% of
preferred stock only) then the gov only get's a benefit of 25% x $10B = $2.5B. So, we're getting snookered even worse here. We've not been repaid and we've given the bank another $7.5B in taxpayer money. Net loss to us = $7.5B
Cliffs: We're getting screwed by some fancy accounting.
Fern