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During 2002, the Corporation reached a tax settlement agreement with the Internal Revenue Service (IRS). This agreement resolved issues for numerous tax returns of the Corporation and various predecessor companies and finalized all federal income tax liabilities through 1999. As a result of the settlement, reductions in income tax expense of $84 million in 2003 and $488 million in 2002 were recorded resulting from refunds received and reductions in previously accrued taxes.
Significant components of the Corporation's deferred tax liabilities and assets at December 31, 2003 and 2002 were as follows:
 |
 |
 |
 |
 |
 |
 |
 |
 |
 |
December 31 |
 |
 |
 |
 |
 |
 |
|
 |
2003 |
 |
2002 |
 |
 |
 |
 |
 |
 |
| Deferred tax liabilities |
 |
| Equipment lease financing |
 |
$ |
5,321 |
 |
$ |
5,767 |
 |
| Intangibles |
 |
955 |
 |
 |
535 |
 |
| Investments |
 |
905 |
 |
 |
700 |
 |
| State taxes |
 |
281 |
 |
 |
310 |
 |
| Depreciation |
 |
246 |
 |
 |
229 |
 |
| Employee retirement benefits |
 |
191 |
 |
 |
250 |
 |
| Deferred gains and losses |
 |
189 |
 |
 |
149 |
 |
| Securities valuation |
 |
- |
 |
 |
350 |
 |
| Available-for-sale debt securities |
 |
- |
 |
 |
266 |
 |
| Other |
 |
560 |
 |
 |
511 |
 |
 |
 |
 |
 |
| Gross deferred tax liabilities |
 |
8,648 |
 |
 |
9,067 |
 |
 |
 |
 |
 |
| Deferred tax assets |
 |
| Allowance for credit losses |
 |
2,421 |
 |
 |
2,661 |
 |
| Securities valuation |
 |
1,876 |
 |
 |
- |
 |
| Accrued expenses |
 |
421 |
 |
 |
412 |
 |
| Employee benefits |
 |
174 |
 |
 |
77 |
 |
| Net operating loss carryforwards |
 |
129 |
 |
 |
315 |
 |
| Loan fees and expenses |
 |
85 |
 |
 |
99 |
 |
| Available-for-sale debt securities |
 |
46 |
 |
 |
- |
 |
| Other |
 |
280 |
 |
 |
212 |
 |
 |
 |
 |
 |
| Gross deferred tax assets |
 |
5,432 |
 |
 |
3,776 |
 |
 |
 |
 |
 |
| Valuation allowance |
 |
(120 |
) |
 |
(114 |
) |
 |
 |
 |
 |
| Gross deferred tax assets, |
 |
| net of valuation allowance |
 |
5,312 |
 |
 |
3,662 |
 |
 |
 |
 |
 |
| Net deferred tax liabilities |
 |
$ |
3,336 |
 |
$ |
5,405 |
 |
 |
 |
 |
 |
The valuation allowance included in the Corporation's deferred tax assets at December 31, 2003 and 2002 represented net operating loss carryforwards for which it is more likely than not that realization will not occur and expire in 2004 to 2009. The net change in the valuation allowance for deferred tax assets resulted from net operating losses being generated by foreign subsidiaries in 2003 where realization is not expected to occur.
At December 31, 2003 and 2002, federal income taxes had not been provided on $871 million and $770 million, respectively, of undistributed earnings of foreign subsidiaries, earned prior to 1987 and after 1997, that have been reinvested for an indefinite period of time. If the earnings were distributed, an additional $185 million and $171 million of tax expense, net of credits for foreign taxes paid on such earnings and for the related foreign withholding taxes, would result in 2003 and 2002, respectively.
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