TAX POLICY & SAVINGS & LOAN CRISIS.   Term Paper ID:21456 Click to get this paper

Essay Subject: Negative economic impact of double-dipping (federal policy allowing S&Ls to deduct losses which were reimbursed tax-free by govt.). Economic Recovery Tax Act of 1981, reform, retroactivity.... More...

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Paper Abstract: Negative economic impact of double-dipping (federal policy allowing S&Ls to deduct losses which were reimbursed tax-free by govt.). Economic Recovery Tax Act of 1981, reform, retroactivity. Paper Introduction: The Savings and Loan Crisis and Double Dipping This paper will discuss federal tax policy as it affected the savings and loan crisis during the late 1980s and early 1990s. Specifically, the paper will examine the problem of "double dipping," whereby savings and loan institutions were allowed to deduct losses which were reimbursed, tax free, by the Federal Savings and Loan Insurance Corporation ("FSLIC"). The first part of the paper will discuss the origins of the crisis and provide an overview of the tax treatment of the losses. The second part of the paper will examine in more detail the special provisions of the Economic Recovery Tax Act of 1981. The third part of the paper will discuss some of the legislative responses to double dipping since the 1981 Act. The fourth part of the paper will examine the issue of the retroactivity of the subsequen Text of the Paper: The entire text of the paper is shown below. However, the text is somewhat scrambled. We want to give you as much information as we possibly can about our papers and essays, but we cannot give them away for free. In the text below you will find that while disordered, many of the phrases are essentially intact. From this text you will be able to get a solid sense of the writing style, the concepts addressed, and the sources used in the research paper. Commissioner, 267 F.2d 127 (1st Cir. The FSLIC entered into manyassistance agreements with troubled institutions in 1988, just before thespecial thrift tax provisions were scheduled to expire (on January 1,1989). The ruling didnot discuss whether FSLIC assistance should be excluded from the amountrealized nor did it examine the applicability of Section 165 to coveredlosses and reimbursed expenses. at 14 -43.[37]Staff of the Joint Comm. 1988), aff'd, 862 F.2d 4 (2d Cir. United States, 444 F.2d 1297 (5th Cir. Washington D.C.: GPO, March 1991. Rul. The ruling simply stated that Section265(1) did not apply to disallow these deductions. Ltr. 1st Sess., 1989. Jacobson, 336 U.S. Chicago, Burlington & Quincy Railroad Co., 412 U.S.4 1, 413 (1973).[2 ]Spragens, Saving the Savings and Loan Industry: Tax Consequences ofFinancial Assistance Payments to Troubled Institutions, 15 J. 28 (1949).DeMartino v. Henry, 3 5 U.S. Therefore, there is nostatutory or legislative basis for allowing a deduction for reimbursedlosses.[29] In addition, the law in this area up through 1981 contained a strongpresumption against implying such a deduction. Under the amount realized rules, in order forSection 597 to implicitly permit double dipping, it is necessary toconclude that Section 597(a)'s exclusion from gross income also requiresthe exclusion of FSLIC assistance from the amount realized under Section1 1. The doctrine of amountrealized and Sections 165 and 166 established the principle that reimbursedlosses are not deductible. H.R. Jacobson, 336 U.S. In 1986, prior to the enactment of the Tax Reform Act of 1986,the Service issued a private letter ruling which seemed to allow adeduction for a loss reimbursed by FSLIC assistance.[34] While debatingthe 1988 Act, Congress heard testimony concerning the assumption thatlosses reimbursed by the FSLIC were deductible. Congressional Record (July 23, 1981), vol. 172.[4]I.R.C. No. 1971).[27]Dosher v. at 1 9.[13]Dept. The second part of thepaper will examine in more detail the special provisions of the EconomicRecovery Tax Act of 1981. In its subsequentreport, the RTC questioned the tax treatment of losses on covered assets.The 1988 agreements had provided acquirers with capital loss protection.Under this scheme, the FSLIC agreed to protect acquirers against lossesrealized on "covered assets."[1 ] Thus, if a covered asset with a bookvalue of $1 was sold for $6 , the FSLIC paid the thrift $4 for the bookloss. Many invested heavily in commercial realestate in the Southwest, which deflated when oil prices plummeted. It has been held that theService is not bound by these rulings except with regard to the taxpayer towhom the ruling is specifically addressed.[44] Legislation may be applied retroactively unless doing so infringesupon constitutional rights.[45] Courts have rarely invalidated retroactivetax statutes. July 23, 1981) (statement of Sen.Boschwitz).[8]Crane, supra note 1, at 1 5-1 6.[9]Pub. The third part of the paper will discuss some ofthe legislative responses to double dipping since the 1981 Act. 1st Sess., pt. 1979).Estate of Bryan v. Bibliography ArticlesCrane, Daniel M. Joint Committee on Taxation. 1959).[45]See e.g., DeMartino v. The fact that the sectionwas later repealed may indicate, then, that Congress later intended torevoke the tax-exempt status.[22] In 1988, the service reversed its previous holding concerning certainFDIC assistance payments. It has long been held that the deduction andexclusion provisions of the Revenue Code are to be strictly construed andthe taxpayer has the burden of showing that he is entitled to adeduction.[26] Deductions are found by examining the language of thestatutes in question and if there exists ambiguity in the language thelegislative history must be reviewed.[27] Thus, weight must also be givento less expansive interpretations of these provisions which preclude doubledipping.[28] As noted above, the drafter's of Section 597 were concerned withhelping the acquirers of troubled thrifts avoid taxable events which woulddissipate the benefit derived from FSLIC assistance. This is not the same,however, as sanctioning a deduction for losses reimbursed by assistance.There is nothing in the Congressional Record which indicates that thedrafters intended to provide such a deduction. Commissioner, 267 F.2d 127, 132 (1st Cir. Henry, 3 5 U.S. As a result, many thrift institutions edged towardscollapse.[1] Recognizing a serious problem, the government first lifted theinterest rate ceilings in 198 in an attempt to make the thrifts morecompetitive. Section597(a) attempted to resolve the issue by providing that FSLIC assistance isexempt from taxation, thus classifying assistance as tax-exempt income. 15 Journal of Corporate Taxation 217-44 (1988). of the Treasury, Report on Tax Issues Relating to the 1988-89Federal Savings and Loan Insurance Corporation Assisted Transactions 9(March 1991).[14]Omnibus Budget Reconciliation Act of 1993, Pub. Supp. Nowhere in Section 597 can it be found that the taxpayer may excludeor disregard FSLIC assistance in determination of the amount realized, thetaxpayer's loss, or the debt's worthlessness or partial worthlessness. 1959).Holder v. [must be] so harsh and oppressive asto transgress the constitutional limitation."[46] In any event, thestatutory provisions allowing double dipping did not do unambiguously andacquirers did not seek a private letter ruling to clarify thisambiguity.[47] Conclusion The issue of the deductibility of losses reimbursed by FSLICassistance during the late 198 s has not yet been resolved. 1988).Dosher v. The subject is rather complexand attempting to rework the 6 -page Crane article into 15 double-spacedpages was extremely difficult.-----------------------[1]Crane, Double Dipping: Congressional Tax Policy and the Savings and LoanCrisis, 13 Va. The reason for thecoexistence of the two subsections probably has to do with the differenttypes of assistance available to thrift institutions. § 382(l)(5)(F).[6]I.R.C. United States, 73 F.2d 375 (5th Cir, 1984).Dunn v. United States, 73 F.2d 375, 376 (5th Cir, 1984).[28]Crane, supra note 1, at 122-23.[29]Id. But the vast majority of the institutions remainedunprofitable since they continued pay out more in deposit interest thanthey earned on long-term fixed rate home mortgages. July 23, 1981) (statement of Sen.Boschwitz).[16]Crane, supra note 1, at 115-16.[17]I.R.C. at 144-45.[4 ]I.R.C. Report No. Department of the Treasury. 13 Virginia Tax Review 1 1-63 (1993).Note. Neither of these conditions has really beenmet with regard to the deductibility of reimbursed losses under Section597. It also contained aprovision which explicitly provides that "[n]o regulation prescribed underthis section shall permit the utilization of any deduction (or other taxbenefit) if such amount was in effect reimbursed by nontaxable federalfinancial assistance."[4 ] This provision was added so that financialinstitutions would "not receive both tax deductions for losses and expensesand an exclusion from gross income of amounts received from the regulatoryinsurance agencies to reimburse the institution (or its successors) forsuch losses and expenses."[41] An amendment to make Section 597(b)(3)retroactive failed. Thus, TAMRA was not conclusive as to Congress'intent.[39] FIRREA, enacted in 199 , abolished the FSLIC and repealed Sections597(a) and (b), leaving FSLIC assistance taxable to the extent that theamount realized exceeds an asset's adjusted tax basis. Government ReportsU.S. S17,128.U.S. Acquirers have inturn stated that they will challenge such action as an arbitrary andcapricious change of policy, and that such action by the Treasury should beestopped by its own prior conduct. Committee Print, 1987.U.S. at 122.[26]Commissioner v. Commissioner, 88 T.C. The Savings and Loan Crisis and Double Dipping This paper will discuss federal tax policy as it affected the savingsand loan crisis during the late 198 s and early 199 s. 1988).[46]Welch v. 99-514, 1 Stat. No. It shifted the risk of loss from the acquirer to the U.S.government and the nation as a whole. at 1 7-1 8.[12]Id. Congress. 991, 995 (S.D.N.Y. Ltr. Thus, assistance ischaracterized as tax-exempt income by Section 597(a) in order to allowassistance to increase E&P.[24] The Legal Context of the Special Provisions It has been argued that Congress intended to provide a tax deductionfor losses reimbursed by the FSLIC. 583 (1987), aff'd without published opinion sub nom, McDonnell v. As with other tax statutes, "the nature of the tax and thecircumstances in which it is laid ... The RTC report questioned the acquirers' practice of disregardingthe FSLIC assistance for the purposes of determining whether the acquirerin such a situation had suffered a tax loss on the transaction. This Act extended the expiration date of the specialthrift tax provisions by one year, to January 1, 1989. This analysis applies to bothSections 165 and 166.[33] Subsequent Legislative Developments Some have argued that the subsequent legislative developmentsdisplayed an intent on the part of Congress to sanction double dipping. 1 1st Cong. Tax Treatment of Savings & Loan Mergers and the FSLIC. Print 1987).[38]Crane, supra note 1, at 243.[39]Id. Thus, TAMRA may be seen asratifying the practice of double dipping, but the ratification was basedupon a mistake of fact. Crane, supra note 1, at 1 7,n. The letter also stated,however, that the existing law in this area was unclear. Besides this ruling,there are no regulations sanctioning such deductions and there are norevenue rulings on the issue.[36] In an explanation of the 1986 Tax Reform Act, the Joint Committeestated that Congress believed that the special thrift rules were"inconsistent with the policies of normal tax rules that otherwise apply"and that acquisitions involving troubled thrifts would be subject to "thegenerally applicable rules" after the special rules expired.[37] TheCommittee did not explain what it meant by "inconsistent." The Act didcontain a new provision, Section 9 4(c)(2)(B), which provided that Section265(1) did not apply so as to disallow otherwise allowable deductionsallocable to the receipt of tax-exempt FSLIC assistance under Section 597.But a compensated loss is not allowable under Section 165, as explainedabove, and Section 265 and the clarification may be irrelevant to theissue.[38] The issue of the deductibility of covered losses was raised duringthe consideration of the Technical Corrections and Miscellaneous RevenueAct of 1988 (TAMRA). 28, 49 (1949); see also, Holder v.United States, 444 F.2d 1297, 13 (5th Cir. Tax'n217, 237 (1988).[21]Pub. 583, 587 (1987), aff'dwithout published opinion sub nom, McDonnell v. 2.U.S. Existing case law requires strict interpretation oftax statutes and the allowance of deductions only where the statutorylanguage clearly creates them. 1 43, 1 47-48 (1989).[2]Crane, supra note 1, at 1 4; Note, supra note 1, at 1 48.[3]Pub. In addition, theassistance should not be deemed compensation for services (which isnormally characterized as income) because there were no facts whichrevealed any specific services to be rendered by either corporationinvolved to the FDIC.[18] The Service had essentially followed the guidelines established bythe Supreme Court in earlier case history. In neither instance did italter the provisions. Commissioner, 862 F.2d 3 8(3d Cir. This double dipping was costing the government in excess of$11.5 billion.[11] In 1991, the Treasury Department issued a report stating that forpolicy reasons assisted institutions should not be allowed a deduction forreimbursed losses or expenses. United States, 468 F. 8835 57 (June 1 , 1988); Priv. Thefirst part of the paper will discuss the origins of the crisis and providean overview of the tax treatment of the losses. 312, § 13224.; See Crane, supra note 1, at 111-113.[15]See 127 Cong. None of the other materials went intonearly as much detail as the Crane article. 991 (S.D.N.Y. Senator Boschwitz speaking for the Economic Recovery Tax Act of 1981. TheTreasury concluded in its 1991 Report that FSLIC assistance payments shouldbe included in the amount realized from a sale, saying that the right of aninstitution to receive assistance on the disposition of a covered assetshould be considered an integral part of the asset.[3 ] Commentators haveagreed, arguing that the amount of FSLIC assistance to which an acquirer isentitled is directly connected to the disposition of the asset.[31] Even if FSLIC assistance is determined to be excluded from the amountrealized on the disposition of the covered asset, Sections 165 and 166 willgenerally be interpreted as preventing a deduction for the loss. S17,128 (daily ed. Senate. 8243 25 (July 22, 1982).[19]United States v. 27, 1988).Note To Client There isn't much published material in this area; the Crane articlewas the latest work I could find. Chicago, Burlington & Quincy Railroad Co., 412 U.S. L. § 118.[18]Priv. Courts have overturned retroactiverevenue rulings in cases where such action "would alter establishedprinciples of tax law implicitly approved by Congress, lead to unequaltreatment among similarly situated taxpayers, or be unduly harsh if appliedto a specific case."[43] The Service never issued regulations or a formalrevenue ruling concerning covered losses; its only guidance was in the formof a non-precedential private letter ruling. Congress responded tothe continuing crisis by pursuing a policy of deregulation and taxincentives for mergers.[2] The Economic Recovery Tax Act of 1981 (ERTA)[3]included three provisions which promoted the acquisition of failing thriftinstitutions: Section 368(a)(3)(D) allowed the acquisition of an insolventthrift to qualify as a tax-free "G" reorganization without regard to thecontinuity of interest rule, giving the acquiring institution a carryoverbasis in the assets of the acquired thrift;[4] Section 382(l)(5)(F)permitted net operating loss (NOL) carryforwards of an insolvent thrift tobe used without the general annual use limitation imposed by Section 382 onNOL carryforwards following an acquisition;[5] and Section 597 providedthat any assistance payments from a deposit insurance agency would bereceived tax-free and not require any downward adjustment in basis.[6] Theintention behind these actions was to encourage the private sector to bearthe burdens of the costs of saving the troubled thrifts and to eliminatethe uncertainty in the tax law concerning the consequences of capitalinfusions and mergers.[7] In spite of these measures, however, the thrift industry remained introuble throughout the 198 s. Up through that period, thriftsacquired most of their income from fixed rate, long-term home mortgageswhich had been set at relatively low interest rates; these institutionswere required by law to invest most of their assets in low-yield homemortgages. Corp. In the most recent case priorto the Service's decision, the Court had set forth five characteristics ofa non-shareholder capital contribution: (1) the contribution must become apermanent part of the transferee's working capital; (2) it must not becompensation for services; (3) it must be bargained for; (4) the assettransferred must result in a benefit for the transferee commensurate withits value; and (5) the asset must be employed in or contribute to theproduction of additional income for the transferee.[19] FDIC and FSLICassistance met all of these criteria. 8912 43 (Dec.27, 1988).[24]Crane, supra note 1, at 12 -21.[25]Id. 1 th Cong., 1st Sess. Onthe other hand, Section 597(b) provides that receipt of FSLIC assistancewill not trigger a reduction in basis, thus implying that such assistancecould be considered contribution to capital. It has been argued, therefore, that Congressratified the private letter ruling.[35] The letter ruling held that acquirers could deduct losses on coveredassets reimbursable through FSLIC tax-exempt assistance. 42 Tax Lawyer 1 43-71 (1989).Spragens, Janet R. Ltr. House. The large number of agreements made during the last few months of1988 locked the government into paying assistance to many institutions.[8] In 1989, when considering the Financial Institutions Reform, Recoveryand Enforcement Act ("FIRREA")[9], Congress authorized the Resolution TrustCorporation (RTC) to review the 1988 FSLIC deals. Even if Section 597(a) was onlyintended to clarify the existing law, the question remains as to why theentire section was repealed by the 1986 Tax Reform Act.[21] It has beensuggested that Congress was originally unclear as to the character ofassistance payments under the law prior to 1981; Section 597(a) was addedto ensure that these payments were not taxable. L. Thus,Congressional clarification of the law was needed.[12] Examining thelegislative record of the 1981 Act, the report concluded that whileCongress intended that the FSLIC assistance not be reduced by theimposition of taxes, Congress did not perceive the deductibility of lossesto be crucial to the purpose of the Act. By1987, the FSLIC reported an overall annual net loss of $6.6 billion and areserve fund deficit of $13.7 billion. Congress. Congress. 134, 147 (1938).[47]Crane, supra note 1, at 159-6 . Section165(a) provides for a deduction of any loss which is "not compensated forby insurance or otherwise." This language has been interpreted as meaning"that the type of compensation received must be such that it was structuredto replace what was lost."[32] FSLIC assistance is tied directly tocovered losses and cannot be separated from the transaction which generatedthe loss. Rec. Rec. 2 at 26 (1989).[42]Crane, supra note 1, at 148-49.[43]Dunn v. As the inflation rate remained high over a long period of time,however, thrifts began paying more in interest on their deposit liabilitiesthan they could earn from their investments in fixed rate home mortgages.While these institutions were prevented by law from raising the amount ofinterest they could pay, depositors began moving their money from low-yieldthrift deposit accounts to more lucrative money market accounts in non-thrift institutions. Rul. 1 1-73, 1 3 Stat. No. It held that assistance payments whicheliminated a troubled institution's negative shareholder equity constitutedtax-exempt income which created earnings and profits (E&P).[23] This wasimportant because capital contributions would not increase E&P;distributions to shareholders in excess of E&P resulted in a taxable eventto the institution through the recapture of its bad debt reserves underSection 593(e). They range incharacter from interest income to capital contribution; thus, assistancemay be either.[16] The Internal Revenue Service initially characterized FSLIC assistanceas non-shareholder capital contribution which would not be includible asgross income.[17] In a private letter ruling in 1982, the IRS noted thatFDIC assistance to a bank, which was in the form of a ten-year notecarrying interest at 12%, was made to promote the stability of banksthroughout the country and to preserve the integrity of the banking system. The assistance payments wereintended to improve the recipient's capital structure; they were notcompensation for any services; they were bargained for, since assistancemust be negotiated; the amounts transferred do have value to the recipientcommensurate with its value; finally, the assistance payments will beemployed in or contribute to the production of additional income.[2 ] However, treating assistance as capital contributions negates thepurpose and effect of Section 597(a). at 122-23.[3 ]Treasury Report, supra note 13, at 9.[31]Crane, supra note 1, at 126-27.[32]Estate of Bryan v. S17,128 (daily ed. The possibility andpractice of double dipping were brought to the attention of Congress bywitnesses, but it extended the provisions for another year because itbelieved that the tax benefits from double dipping would reduce the amountof FSLIC assistance required, without providing a windfall to acquirers.This assumption turned out to be false. Tax Rev. 1 1, 1 3-1 4 (1993); Note, Tax Treatment of Savings& Loan Mergers and the FSLIC, 42 Tax Law. Introduction The crisis in the savings and loan industry had its origins duringthe inflationary economy of the 197 s. Since both of these purposes are public benefits of the type traditionallyheld to be consistent with capital contribution treatment, FDIC assistanceshould be characterized as capital contribution. on Taxation, 1 th Cong., 1st Sess., GeneralExplanation of the Tax Reform Act of 1986, at 571 (Comm. The fourthpart of the paper will examine the issue of the retroactivity of thesubsequent legislative actions in the area. 4 1(1973).Welch v. Saving the Savings and Loan Industry: Tax Consequences of Financial Assistance Payments to Troubled Institutions. 18[11]Id. Commissioner, 74 T.C 725, 727 (198 ).[33]Crane, supra note 1, at 133-39.[34]Priv. No. While the Act was being debated in Congress, one issue which washighlighted but never clearly resolved was whether FSLIC assistance shouldbe considered contribution to capital or tax-exempt income.[15] Thisconfusion had existed under the previous version of Section 597. Commissioner, 74 T.C 725 (198 ).Goodstein v. 8637 5 (May 3 , 1986).[35]Crane, supra note 1, at 139-41.[36]Id. 97-34, 95 Stat. In1986 and 1988, Congress extended the special tax provisions enacted by ERTAin 1981. 1988), aff'd, 862 F.2d 4 (2d Cir. Thishigh carryover basis, which resulted from Section 368(a)(3)(D), implied adeduction for reimbursed losses; there would be no logical reason otherwisefor the high carryover basis.[25] Opponents of double dipping, however, argue that while theseprovisions are not inconsistent with double dipping, they do notaffirmatively authorize it. In addition, Congress did notadequately consider the implications of this deductibility and the"perverse incentives" associated with it.[13] Since the RTC and Treasury reports were issued, Congress hasattempted to take action to eliminate deductions for covered losses.Several bills made their way through both Houses, all containing provisionswhich limited the ability of acquirers to deduct losses which werecompensated. No. Rul. 1979).[44]Goodstein v. In August of 1993, a bill was signed into law which assertedthat double dipping is not permitted.[14] The Special Thrift Tax Provisions of the 1981 Act FSLIC Assistance: Contribution to Capital or Tax-Exempt Income? § 597.[7]127 Cong. 134 (1938).Treasury RulingsPrivate Letter Ruling 8243 25 (July 22, 1982).Private Letter Ruling 8637 5 (May 3 , 1986).Private Letter Ruling 8835 57 (June 1 , 1988).Private Letter Ruling 8912 43 (Dec. 1971).United States v. Thus, it is analogous to insurance in that it provides capital lossprotection. 54, 1 1st Cong. § 597(b)(3).[41]H.R. Acquirerswere declaring tax losses, even though these losses were fully compensated;in addition, the acquirers were allowed to treat the FSLIC assistance astax-exempt. L. Commissioner, 88 T.C. L. Specifically, thepaper will examine the problem of "double dipping," whereby savings andloan institutions were allowed to deduct losses which were reimbursed, taxfree, by the Federal Savings and Loan Insurance Corporation ("FSLIC"). In addition, it seems likely that new legislation may be appliedretroactively to the assistance agreements made in late 1988. Supp. Such a deduction, explained Secretary Bradyin a letter accompanying the report, induces institutions to hold coveredassets and minimize their value when sold. Rep. CasesCommissioner v. 183.[1 ]"Covered assets" include real estate owned by the thrift, loans invarious stages of default, delinquent loans, non-investment gradesecurities, and investment in subsidiaries. 127, p. General Explanation of the Tax Reform Act of 1986. This failure has been used as part of the argumentthat Congress intended to allow double dipping by those involved in the1988 transactions to continue.[42] Retroactivity The Treasury has stated that it will challenge deductions forcompensated losses, even if legislation is not enacted. Double Dipping: Congressional Tax Policy and the Savings and Loan Crisis. 1 3-66, 1 7Stat. Commissioner, 862 F.2d 3 8 (3d Cir. The losses to an institution during a merger oftenconsumed the acquiring institution's E&P and impaired its ability to makedistributions without triggering Section 593(e). § 368(a)(3)(D).[5]I.R.C. The government was obligated to provide the assistance when theacquirer disposed of an asset for less than its adjusted basis or bookvalue. Ltr. 2 85.[22]Spragens, supra note 2 , at 238-39.[23]Priv. Congress must haverealized that Section 597 would give rise to loss deductions as a result ofthe high carryover basis in assets acquired from a failed thrift. United States, 468 F. 54, pt. Report on Tax Issues Relating to the 1988- 89 Federal Savings and Loan Insurance Corporation Assisted Transactions. Despite theassertions of the thrift industry, it seems unlikely that Congress intendedto create a double tax benefit for troubled savings and loans, especiallyone which promoted the devaluation of assets and their disposition atextremely low prices. Rul. These proponents of double dippingargue that the three special provisions in the 1981 Act, when readtogether, permit the deduction of reimbursed losses. 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