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Income Taxes And Tax-Related Items | 12 Months Ended
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Dec. 31, 2023
Income Tax Disclosure [Abstract] |
Income Taxes and Tax-Related Items | INCOME TAXES AND TAX-RELATED ITEMS The provision for income taxes is calculated as the sum of income taxes due for the current year and deferred taxes. Income taxes due for the current year are computed by applying federal and state tax statutes to current year taxable income. Deferred taxes arise from temporary differences between the income tax basis and financial accounting basis of assets and liabilities. Tax-related interest and penalties and foreign taxes are then added to the tax provision. The current and deferred components of the provision for income taxes were as follows:
(in millions) |  |  |  |  |
December 31 | 2023 |  | 2022 |  | 2021
Current: |  |  |  |  |
Federal | $ | 297 |  |  | $ | 296 |  |  | $ | 212 |
Foreign | 9 |  |  | 6 |  |  | 5 |
State and local | 49 |  |  | 50 |  |  | 26 |
Total current | 355 |  |  | 352 |  |  | 243 |
Deferred: |  |  |  |  |
Federal | (83) |  |  | (24) |  |  | 62 |
State and local | (9) |  |  | (3) |  |  | 17 |
Total deferred | (92) |  |  | (27) |  |  | 79 |
Total | $ | 263 |  |  | $ | 325 |  |  | $ | 322 |
Income before income taxes of $1.1 billion for the year ended December 31, 2023 included $87 million of foreign taxable income. The provision for income taxes does not reflect the tax effects of unrealized gains and losses on investment securities available-for-sale, hedging transactions or the change in defined benefit pension and other postretirement plans adjustment included in accumulated other comprehensive (loss) income. Refer to Note 14 for additional information on accumulated other comprehensive (loss) income. A reconciliation of expected income tax expense at the federal statutory rate to the Corporation’s provision for income taxes and effective tax rate follows:
(dollar amounts in millions) | 2023 |  | 2022 |  | 2021
Years Ended December 31 | Amount |  | Rate |  | Amount |  | Rate |  | Amount |  | Rate
Tax based on federal statutory rate | $ | 240 |  |  | 21.0 | % |  | $ | 310 |  |  | 21.0 | % |  | $ | 313 |  |  | 21.0 | %
State income taxes | 35 |  |  | 3.1 |  |  | 36 |  |  | 2.5 |  |  | 35 |  |  | 2.4 |
Affordable housing and historic credits | (16) |  |  | (1.4) |  |  | (13) |  |  | (0.9) |  |  | (13) |  |  | (0.9) |
Bank-owned life insurance | (10) |  |  | (0.9) |  |  | (10) |  |  | (0.7) |  |  | (10) |  |  | (0.6) |
FDIC insurance expense | 15 |  |  | 1.3 |  |  | 6 |  |  | 0.4 |  |  | 5 |  |  | 0.3 |
Employee stock transactions | (1) |  |  | (0.1) |  |  | (3) |  |  | (0.2) |  |  | (3) |  |  | (0.2) |
Tax-related interest and penalties | (4) |  |  | (0.4) |  |  | — |  |  | — |  |  | — |  |  | — |
Other | 4 |  |  | 0.4 |  |  | (1) |  |  | (0.1) |  |  | (5) |  |  | (0.4) |
Provision for income taxes | $ | 263 |  |  | 23.0 | % |  | $ | 325 |  |  | 22.0 | % |  | $ | 322 |  |  | 21.6 | %
The liability for tax-related interest and penalties, included in accrued expenses and other liabilities on the Consolidated Balance Sheets, was less than $1 million and $5 million at December 31, 2023 and 2022, respectively. The decrease in tax-related interest and penalties was primarily due to a state settlement received in 2023. In the ordinary course of business, the Corporation enters into certain transactions that have tax consequences. From time to time, the Internal Revenue Service (IRS) may review and/or challenge specific interpretive tax positions taken by the Corporation with respect to those transactions. The Corporation believes that its tax returns were filed based upon applicable statutes, regulations and case law in effect at the time of the transactions. The IRS or other tax jurisdictions, an administrative authority or a court, if presented with the transactions, could disagree with the Corporation’s interpretation of the tax law. A reconciliation of the beginning and ending amount of net unrecognized tax benefits follows:
(in millions) | 2023 |  | 2022 |  | 2021
Balance at January 1 | $ | 16 |  |  | $ | 18 |  |  | $ | 19 |
(Decrease) increase as a result of tax positions taken during a prior period | — |  |  | (2) |  |  | 1 |
Increase as a result of tax positions taken during the current period | 1 |  |  | 3 |  |  | 3 |
Decreases related to settlements with tax authorities | (10) |  |  | (3) |  |  | (3) |
Reduction as a result of expiration of statute of limitations | — |  |  | — |  |  | (2) |
Balance at December 31 | $ | 7 |  |  | $ | 16 |  |  | $ | 18 |
After consideration of the effect of the federal tax benefit available on unrecognized state tax benefits, the total amount of unrecognized tax benefits which, if recognized, would affect the Corporation’s effective tax rate was approximately $5 million and $13 million at December 31, 2023 and 2022, respectively. The following tax years for significant jurisdictions remain subject to examination as of December 31, 2023:
Jurisdiction | Tax Years
Federal | 2020-2022
New York | 2018-2022
California | 2020-2022
Based on current knowledge and probability assessment of various potential outcomes, the Corporation believes current tax reserves are adequate, and the amount of any potential incremental liability arising is not expected to have a material adverse effect on the Corporation’s consolidated financial condition or results of operations. Probabilities and outcomes are reviewed as events unfold, and adjustments to the reserves are made when necessary. The principal components of deferred tax assets and liabilities were as follows:
(in millions) |  |  |
December 31 | 2023 |  | 2022
Deferred tax assets: |  |  |
Allowance for loan losses | $ | 145 |  |  | $ | 128 |
Deferred compensation | 77 |  |  | 84 |
Deferred loan origination fees and costs | 11 |  |  | 12 |
Net hedging losses | 186 |  |  | 290 |
Net unrealized losses on investment securities available-for-sale | 628 |  |  | 713 |
Operating lease liabilities | 81 |  |  | 85 |
Other temporary differences, net | 124 |  |  | 42 |
Total deferred tax assets before valuation allowance | 1,252 |  |  | 1,354 |
Valuation allowance | (6) |  |  | (5) |
Total deferred tax assets | 1,246 |  |  | 1,349 |
Deferred tax liabilities: |  |  |
Lease financing transactions | (20) |  |  | (31) |
Defined benefit plans | (159) |  |  | (123) |
Allowance for depreciation | (5) |  |  | (4) |
Leasing right of use assets | (67) |  |  | (71) |
Total deferred tax liabilities | (251) |  |  | (229) |
Net deferred tax assets | $ | 995 |  |  | $ | 1,120 |
Deferred tax assets included $5 million and $4 million of federal foreign tax credit carryforwards at December 31, 2023 and 2022, respectively, expiring between 2028 and 2032. In addition, there were $2 million of state net operating loss (NOL) carryforwards at both December 31, 2023 and 2022, expiring between 2024 and 2042. The Corporation believes it is more likely than not that the benefit from federal foreign tax credits and certain state NOL carryforwards will not be realized and, accordingly, maintains a federal valuation allowance of $5 million and a state valuation allowance of $1 million at December 31, 2023, compared to a federal valuation of $4 million and a state valuation allowance of $1 million in the comparable period in 2022. For further information on the Corporation’s valuation policy for deferred tax assets, refer to Note 1.

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