OAR 150-317-0370
Bad Debt Reserve of Financial Institutions that Have Changed From Reserve Method to Specific Charge-off Method


(1)

For tax years beginning on or after January 1, 1987, Oregon has adopted the federal provisions for treatment of bad debts of financial institutions provided in Section 585(c) of the Internal Revenue Code (IRC). Financial institutions considered large banks, defined in IRC 585(c)(2), must recapture the balance in their reserve for bad debts over a four-year period unless they elect the federal “cut-off” method.

(a)

The recapture provisions of IRC 585(c)(3) shall be applied to the ending reserve balance calculated for Oregon tax purposes for the 1986 tax year.

(b)

For each of the four recapture years, an Oregon addition modification shall be made if the Oregon reserve recaptured exceeds the federal reserve recaptured. An Oregon subtraction modification shall be made if the federal reserve recaptured exceeds the Oregon reserve recaptured.
Example: Lending Corp., a calendar year filer, has a bad debt reserve of $5,000,000 for federal and $3,000,000 for Oregon tax purposes on December 31, 1986. Lending Corp. qualifies as a large bank. It elects to recapture 10 percent of the bad debt reserve as income on its 1987 federal return. An Oregon subtraction modification of $200,000 is calculated as follows: [Table not included. See ED. NOTE.]

(c)

Financially troubled banks don’t have to recapture existing bad debt reserves as long as their nonperforming loans exceed seventy-five percent of the average of their equity capital for the year.

(2)

Oregon also adopted the cut-off method provided under IRC 585(c)(4) for tax years beginning on or after January 1, 1987. If the financial institution elects the cut-off method, the ending balance of the reserve for bad debts for the 1986 tax year shall not be recaptured. Instead, bad debts in tax years after 1986 shall be charged to the reserve rather than deducted from income. When the entire reserve has been depleted, bad debts shall be deducted as they occur.

(a)

The provisions in IRC 585(c)(4) shall be applied to the ending reserve balance calculated for Oregon tax purposes for the 1986 tax year.

(b)

The ending balance of the reserve for bad debts as of December 31, 1986, may be greater for federal purposes than it is for Oregon. If so, the Oregon reserve will be depleted before the federal reserve. An Oregon subtraction modification shall be made when the Oregon deduction for bad debts exceeds the federal deduction for the tax year.
Example: Large Bank, Inc., elected the cut-off method of treating its reserve for bad debts, starting in 1987. The reserve balance on January 1, 1991, was $100,000 for federal purposes and $50,000 for Oregon purposes. During 1991, $150,000 of bad debts were written off. An Oregon subtraction modification of $50,000 is calculated as follows: [Table not included. See ED. NOTE.]

(c)

The ending balance of the reserve for bad debts as of December 31, 1986, may be greater for Oregon purposes than it is for federal. If so, the federal reserve will be depleted before the Oregon reserve. An Oregon addition modification shall be made when the federal deduction for bad debts exceeds the Oregon deduction for the tax year.
[Publications: The publication(s) referred to or incorporated by reference in this rule is available from the Department of Revenue pursuant to ORS 183.360 (Publication of rules and orders)(2) and 183.355 (Filing and taking effect of rules)(6).]
[ED. NOTE: To view attachments referenced in rule text, click here to view rule.]

Source: Rule 150-317-0370 — Bad Debt Reserve of Financial Institutions that Have Changed From Reserve Method to Specific Charge-off Method, https://secure.­sos.­state.­or.­us/oard/view.­action?ruleNumber=150-317-0370.

150–317–0010
Procedure for Handling State Surplus Refund
150–317–0020
Substantial Nexus Guidelines
150–317–0030
Definition: “Doing Business”
150–317–0040
Taxable Income of Regulated Investment Companies and Real Estate Investment Trusts
150–317–0050
Foreign Corporations Subject to Tax
150–317–0060
Capital Losses — Carrybacks and Carry-overs
150–317–0070
Administrative and Judicial Interpretations
150–317–0080
Adoption of Federal Law
150–317–0090
Policy — Application of Various Provisions of the Federal Internal Revenue Code
150–317–0100
Periods of Less than 12 Months Are Tax Years
150–317–0110
Tax Reform Act of 1984 Adjustments
150–317–0120
Farm Capital Gain
150–317–0130
Tax on Homeowner’s Association Income
150–317–0140
Imposition of the Tax: Mercantile, Manufacturing and Business Corporations
150–317–0150
Adoption of Federal Exempt Organizations
150–317–0160
Exemption and Return Requirements
150–317–0170
Minimum Tax
150–317–0190
Affordable Housing Credit
150–317–0200
Commercial Lending Institution Loans for Underground Storage Tanks or Soil Remediation
150–317–0210
Carryover of the Lender’s Credit for Weatherization Loans
150–317–0220
Lender’s Credit: Loans to Wood Heat and Fuel Oil Heat Customers
150–317–0230
Lender’s Credit: Computation
150–317–0240
Lender’s Credit: Definitions
150–317–0245
Commencement of Long Term Enterprise Zone Tax Credit
150–317–0250
Long Term Enterprise Zone Distributions
150–317–0260
Lender’s Credit for Agriculture Workforce Housing
150–317–0270
Credit for Contributions of Computers, Scientific Equipment, and Research
150–317–0280
Qualified Research Credit
150–317–0290
Research Tax Credit: Notice of Election
150–317–0300
Research Tax Credit: Alternative Computation
150–317–0310
Bad Debt Reserve of Financial Institutions Not Qualifying as Large Banks that Have Differences in Reserve for Federal and Oregon Tax Purposes
150–317–0320
Modification of Federal Taxable Income: Dividends from Certain Subsidiaries
150–317–0330
Modification for Dividends Received
150–317–0340
Modification of Federal Taxable Income: Internal Revenue Code Subpart F Income
150–317–0350
Oregon Subtraction Where Charitable Contribution Is Reduced Under Federal Law
150–317–0360
Definition of “State”
150–317–0370
Bad Debt Reserve of Financial Institutions that Have Changed From Reserve Method to Specific Charge-off Method
150–317–0380
Taxes on Net Income or Profits Imposed by any State or Foreign Country
150–317–0390
IRC Section 338: Application to Oregon
150–317–0400
Payments Received Under Federal Safe Harbor Lease Agreements For Transactions Entered Into in Tax Years Beginning on or After January 1, 1983
150–317–0410
Payments Received Under Federal Safe Harbor Lease Agreements for Transactions Entered Into in Tax Years Beginning Prior to 1983
150–317–0420
Modification of Federal Taxable Income: Difference Between Oregon and Federal Bases on Assets Sold, Exchanged or Otherwise Disposed Of
150–317–0430
Modification of Federal Taxable Income: Timber Cut but Unsold
150–317–0440
Depletion Allowance
150–317–0450
Depletion of Metal Mines
150–317–0460
Limitation on Oregon Net Loss Deduction
150–317–0470
Pre-change and Built-in Losses
150–317–0480
Definition of “Premiums” in the Insurance Sales Factor
150–317–0490
Insurers
150–317–0500
Applicable Date
150–317–0510
Unitary Business
150–317–0520
Direct or Indirect Relationships
150–317–0530
Corporations Doing Business Outside the United States
150–317–0540
Consolidated Oregon Return: Format and Information Required
150–317–0550
Consolidated Oregon Return: Affiliated Group
150–317–0560
Consolidated Oregon Return: Credits
150–317–0570
Different Apportionment Factors for Purposes of ORS 317.710(5)(b)
150–317–0580
Consolidated Oregon Return: Copy of Federal Return Required
150–317–0590
Interinsurance and Reciprocal Exchanges
150–317–0600
Limitations on Deduction of Group Losses
150–317–0610
Modified Federal Consolidated Taxable Income
150–317–0620
Modified Federal Consolidated Taxable Income — Contribution Deduction for the Oregon Consolidated Group
150–317–0630
Oregon Return: Apportionment Formula
150–317–0640
Member of a Unitary Group Incorporated in a Listed Foreign Jurisdiction
150–317–0650
Stakeholder feedback regarding listed jurisdictions
150–317–0651
Repatriation Tax Credit
150–317–0652
Modification for Listed Jurisdiction Amounts Previously Included in Income
150–317–0660
Computation of Taxable Income
150–317–0670
Application for Relief
150–317–0680
Tax Imposed on Unrelated Business Income of Certain Exempt Corporations
150–317–1000
Definition of Commercial Activity
150–317–1010
Substantial Nexus Guidelines for the Corporate Activity Tax (CAT)
150–317–1020
Corporate Activity Tax Unitary Business Factors, Common Ownership and Filing Requirements for Unitary Groups
150–317–1025
Corporate Activity Tax: Election to Exclude Non-U.S. Members from Unitary Group
150–317–1030
Sourcing Commercial Activity to Oregon from Sales of Tangible Personal Property
150–317–1040
Sourcing Commercial Activity to Oregon of Other than Sales of Tangible Personal Property
150–317–1050
Sourcing of Commercial Activity for Financial Institutions in This State
150–317–1060
Definition of Insurers’ Gross Premiums Receipts
150–317–1070
Sourcing of Motor Carrier Transportation Services
150–317–1100
Agent Exclusion
150–317–1120
Exclusion for subcontracting payments
150–317–1130
Property Brought into Oregon
150–317–1140
Wholesale Sale of Groceries Exclusion
150–317–1150
Retail Sale of Groceries Exclusion
150–317–1160
Farmer’s Sales to Agricultural Cooperatives
150–317–1170
Farming Operations: Clarifying Definitions for Agricultural Commodities, Farming Operations, Out of State Sales Based on Industry Averages
150–317–1200
Cost Input or Labor Cost Subtraction
150–317–1220
Employee Compensation: Labor Cost Subtraction
150–317–1300
Estimated Tax: When Estimated Payments Are Required
150–317–1310
Estimated Tax Payments: Delinquent or Underestimated Payment or Both, Constitutes Underpayment
150–317–1320
Estimated Tax: Unitary Groups and Apportioned Returns
150–317–1330
Extension of Time to File
150–317–1400
Determining Property Resold Out of State, and Methods of Determining
150–317–1410
Motor Vehicle Resale Certificate – Documentation Required
150–317–1420
Damages Received as the Result of Litigation
150–317–1500
Good Faith Effort
Last Updated

Jun. 8, 2021

Rule 150-317-0370’s source at or​.us