Insurance guarantee association

From the 2024 DOR Tax Exemption Study

relevant documentation establishing that Taxpayer has a legally enforceable interest in the underlying trust assets of its MBS and HMBS investments, Taxpayer has failed to meet its burden of proving that it is entitled to the deduction under RCW 82.04.4292. Budget Rent-A-Car, 81 Wn. 2d at 174-75. . . . Det. No. 20-0061, 41 WTD 337 (October 26, 2022) 343 2. Deduction for Interest Earned on Obligations of the Federal Government Banks, savings and loan associations, and other financial institutions [may deduct] interest income received on direct obligations of the Federal Government. RCW 82.04.4286; Rule 146(3); Det. No. 89-476, 8 WTD 271 (1989). RCW 82.04.4286 recognizes a deduction from the measure of B&O tax for “amounts derived from business which the state is prohibited from taxing under the Constitution of this state or the Constitution or laws of the United States.” This is consistent with 31 U.S.C. § 3124(a) (formerly codified as 31 U.S.C. § 742, with minor variations in its language), which bars states from taxing “[s]tocks and obligations of the United States Government,” subject to certain exceptions. Rule 146 explains how RCW 82.04.4286 applies to income earned by banks a