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Income Taxes
 12 Months Ended
Dec. 31, 2024
Income Taxes  
Income Taxes

15. Income Taxes

​

For the years ended December 31, 2024, 2023 and 2022, the provision (benefit) for income taxes was comprised of the following:

​

​

​

​

​

​

​

​

​

​

​

​

​

Year Ended December 31, 

(dollars in thousands)

  

2024

  

2023

  

2022

Current:

​

​

​

​

​

​

​

​

​

Federal

​

$

57,006

​

$

66,123

​

$

50,895

State and local

​

​

16,754

​

​

21,724

​

​

12,493

Total current

​

​

73,760

​

​

87,847

​

​

63,388

Deferred:

​

​

​

​

​

​

​

​

​

Federal

​

​

(4,756)

​

​

(8,387)

​

​

13,639

State and local

​

​

(6,531)

​

​

(5,269)

​

​

8,499

Total deferred

​

​

(11,287)

​

​

(13,656)

​

​

22,138

Total provision for income taxes

​

$

62,473

​

$

74,191

​

$

85,526

​

The Company files Federal and state income tax returns for its subsidiaries. The Company’s subsidiary also files income tax returns in Guam, Saipan and certain other state jurisdictions. The Company had a current income tax receivable due from various jurisdictions of $25.5 million and $30.9 million as of December 31, 2024 and 2023, respectively, for its share of consolidated and combined tax overpayments that had not yet been received.

​

The components of net deferred income tax assets and liabilities at December 31, 2024 and 2023, were as follows:

​

​

​

​

​

​

​

​

​

​

December 31, 

(dollars in thousands)

  

2024

  

2023

Assets:

​

​

​

​

​

​

Deferred compensation expense

​

$

52,192

​

$

50,945

Allowance for credit losses and nonperforming assets

​

​

51,922

​

​

51,492

Lease liabilities

​

​

16,808

​

​

17,027

Investment securities

​

​

171,258

​

​

194,213

State income taxes

​

​

1,939

​

​

2,514

Total deferred income tax assets

​

​

294,119

​

​

316,191

Liabilities:

​

​

​

​

​

​

Leases

​

​

(8,457)

​

​

(13,283)

Deferred income

​

​

(7,151)

​

​

(12,751)

Lease right-of-use assets

​

​

(16,041)

​

​

(16,364)

Intangible assets

​

​

(973)

​

​

(948)

Other

​

​

(30,292)

​

​

(33,320)

Total deferred income tax liabilities

​

​

(62,914)

​

​

(76,666)

Net deferred income tax assets

​

$

231,205

​

$

239,525

​

Net deferred income tax assets were included in other assets in the consolidated balance sheets as of December 31, 2024 and 2023.

​

Realization of deferred tax assets is dependent on sufficient taxable income being generated in the future and, although realization is not assured, the Company believes it is more likely than not that all of the deferred tax assets will be realized. However, if estimates of future taxable income decrease, a reduction to the amount of deferred tax assets considered realizable could result.

​

The following analysis reconciles the Federal statutory income tax rate to the effective income tax rate for the years ended December 31, 2024, 2023 and 2022:

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​

​

​

​

​

​

​

​

​

​

​

​

​

​

​

​

​

​

​

​

​

Year Ended December 31, 

​

​

​

2024

​

​

2023

​

​

2022

​

(dollars in thousands)

  

Amount

  

Percent

​

​

Amount

  

Percent

​

​

Amount

  

Percent

​

Federal statutory income tax expense and rate

​

$

61,446

​

21.00

%

​

$

64,927

​

21.00

%

​

$

73,754

​

21.00

%

State and local taxes, net of federal income tax benefit

​

​

8,077

​

2.76

​

​

​

13,000

​

4.20

​

​

​

16,584

​

4.72

​

Tax credits

​

​

(4,388)

​

(1.50)

​

​

​

(4,506)

​

(1.46)

​

​

​

(3,963)

​

(1.13)

​

Nontaxable income

​

​

(5,604)

​

(1.92)

​

​

​

(6,691)

​

(2.16)

​

​

​

(1,133)

​

(0.32)

​

Other

​

​

2,942

​

1.01

​

​

​

7,461

​

2.42

​

​

​

284

​

0.08

​

Income tax expense and effective income tax rate

​

$

62,473

​

21.35

%

​

$

74,191

​

24.00

%

​

$

85,526

​

24.35

%

​

The Company is subject to examination by the Internal Revenue Service (“IRS”) and tax authorities in states in which the Company has significant business operations. The tax years under examination and open for examination vary by jurisdiction. Currently, refund claims and tax returns for certain years are being reviewed by state jurisdictions. No material adjustments are anticipated as a result of these examinations and reviews. The Company’s income tax returns for 2021 and subsequent tax years generally remain subject to examination by U.S. federal and foreign jurisdictions, and 2020 and subsequent years are subject to examination by state taxing authorities.

​

A reconciliation of the amount of unrecognized tax benefits is as follows for the years ended December 31, 2024, 2023 and 2022:

​

​

​

​

​

​

​

​

​

​

​

​

​

​

​

​

​

​

​

​

​

​

​

​

​

​

​

​

​

​

​

Year Ended December 31, 

​

​

2024

​

2023

​

2022

​

​

​

​

​

Interest

​

​

​

​

​

​

​

Interest

​

​

​

​

​

​

​

Interest

​

​

​

​

​

​

​

​

and

​

​

​

​

​

​

​

and

​

​

​

​

​

​

​

and

​

​

​

(dollars in thousands)

  

Tax

  

Penalties

  

Total

  

Tax

  

Penalties

  

Total

  

Tax

  

Penalties

  

Total

Balance at beginning of year

​

$

185,461

​

$

26,584

​

$

212,045

​

$

183,751

​

$

22,474

​

$

206,225

​

$

183,311

​

$

20,743

​

$

204,054

Additions for current year tax positions

​

​

653

​

​

—

​

​

653

​

​

629

​

​

—

​

​

629

​

​

1,289

​

​

—

​

​

1,289

Additions for Reorganization Transactions

​

​

—

​

​

2,717

​

​

2,717

​

​

—

​

​

3,155

​

​

3,155

​

​

—

​

​

974

​

​

974

Additions for prior years' tax positions:

​

​

​

​

​

​

​

​

​

​

​

​

​

​

​

​

​

​

​

​

​

​

​

​

​

​

​

New uncertain tax positions identified

​

​

—

​

​

—

​

​

—

​

​

2,220

​

​

—

​

​

2,220

​

​

—

​

​

—

​

​

—

Accrual of interest and penalties

​

​

—

​

​

1,253

​

​

1,253

​

​

—

​

​

1,221

​

​

1,221

​

​

—

​

​

860

​

​

860

Reductions for prior years' tax positions:

​

​

​

​

​

​

​

​

​

​

​

​

​

​

​

​

​

​

​

​

​

​

​

​

​

​

​

Expiration of statute of limitations

​

​

(4,408)

​

​

(1,280)

​

​

(5,688)

​

​

(1,139)

​

​

(266)

​

​

(1,405)

​

​

(849)

​

​

(103)

​

​

(952)

Resolutions with tax authorities

​

​

(2,698)

​

​

(1,890)

​

​

(4,588)

​

​

—

​

​

—

​

​

—

​

​

—

​

​

—

​

​

—

Balance at December 31, 

​

$

179,008

​

$

27,384

​

$

206,392

​

$

185,461

​

$

26,584

​

$

212,045

​

$

183,751

​

$

22,474

​

$

206,225

​

Included in the balance of unrecognized tax benefits for the years ended December 31, 2024, 2023 and 2022, was $51.8 million, $56.4 million and $24.2 million, respectively, of unrecognized tax benefits that, if recognized, would impact the effective tax rate.

​

In connection with the Reorganization Transactions discussed below, the Company recorded unrecognized tax benefits and interest and penalties of $121.4 million and $7.0 million, respectively. Included in the balance of the unrecognized tax benefits as of December 31, 2024, was $141.2 million attributable to tax refund claims with respect to tax years 2005 through 2013 and 2015 in the State of California. Such refund claims were filed by the Company in 2015, 2019 and 2021, on behalf of the Company and its affiliates, including BOW, concerning the determination of taxes for which no benefit is currently recognized. It is reasonably possible that the amount of unrecognized tax benefits could decrease within the next 12 months by as much as $0.6 million of taxes and $0.2 million of accrued interest and penalties as a result of settlements and the expiration of the statute of limitations in various states. On February 1, 2023, Bank of Montreal acquired Bank of the West from BNP Paribas SA. This transaction, and the resulting change in ownership, could affect the unrecognized tax benefits related to the years when the Company was included in consolidated and combined returns with Bank of the West.

​

The Company recognizes interest and penalties attributable to both unrecognized tax benefits and undisputed tax adjustments in the provision for income taxes. For the years ended December 31, 2024, 2023 and 2022, the Company recorded $4.0 million, $4.2 million and $0.8 million, respectively, of net expense attributable to interest and penalties. The Company had a liability of $29.1 million and $28.5 million as of December 31, 2024 and 2023, respectively, accrued for interest and penalties, of which $27.4 million and $26.6 million as of December 31, 2024 and 2023, respectively, were attributable to unrecognized tax benefits and the remainder was attributable to tax adjustments which are not expected to be in dispute.

​

Prior to the Reorganization Transactions, the Company filed consolidated U.S. Federal and combined state tax returns that incorporated the tax receivables and unrecognized tax benefits of FHB and BOW. The consummation of the Reorganization Transactions did not relieve the Company of the pre-Reorganization Transactions tax receivables and unrecognized tax benefits recognized by BOW that were included in the Company's consolidated and combined tax returns. As a result, on April 1, 2016, the Company recorded $72.8 million related to current tax receivables, $116.6 million related to unrecognized tax benefits, and an indemnification payable of $28.6 million. As of December 31, 2024 and 2023, the Company maintained balances of $130.5 million related to current tax receivables. As of December 31, 2024 and 2023, the Company maintained balances of $159.0 million and $160.6 million, respectively, related to unrecognized tax benefits, and an indemnification receivable of $28.5 million and $30.1 million, respectively. Additionally, in connection with the Reorganization Transactions, the Company has incurred certain tax-related liabilities related to the distribution of its interest in BWHI amounting to $95.4 million. The amount necessary to pay the distribution taxes (net of the expected federal tax benefit of $33.4 million) was paid by BNPP to the Company on April 1, 2016. The Company reported total distribution taxes of $92.1 million in the 2016 tax returns of various state and local jurisdictions, and reimbursed BWHI approximately $2.1 million pursuant to a tax sharing agreement entered into on April 1, 2016 and pursuant to certain tax allocation agreements entered into among the parties. The Company expects that any future adjustment to such taxes will be similarly reimbursed to, or funded by, BWHI, BNPP or their affiliates. Accordingly, the assumption of the pre-Reorganization Transactions tax receivables, unrecognized tax benefits and distribution tax liabilities and the offsetting indemnification receivables or payables were reflected as equity contributions and distributions on April 1, 2016. The reimbursement of distribution taxes to BWHI was also reflected as an adjustment to equity. If there are any future adjustments to the indemnified tax receivables or unrecognized tax benefits, an offsetting adjustment to the indemnification receivables or payables will be recorded to the provision for income taxes and other noninterest income or expense. For the years ended December 31, 2024, 2023 and 2022, the Company recorded $2.1 million, $2.5 million and nil, respectively, of such adjustments through the provision for income taxes and noninterest income. In addition, for the year ended December 31, 2024, the Company recorded $3.8 million of such adjustments through the provision for income taxes and noninterest expense.