Citibank 2014 Annual Report Download - page 202

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Based upon the foregoing discussion, Citi believes the U.S. federal and
New York state and city NOL carry-forward period of 20 years provides enough
time to fully utilize the DTAs pertaining to the existing NOL carry-forwards
and any NOL that would be created by the reversal of the future net
deductions that have not yet been taken on a tax return.
The U.S. FTC carry-forward period is 10 years and represents the most
time-sensitive component of Citi’s DTAs. Utilization of FTCs in any year is
restricted to 35% of foreign source taxable income in that year. However,
overall domestic losses that Citi has incurred of approximately $59 billion as
of December 31, 2014 are allowed to be reclassified as foreign source income
to the extent of 50% of domestic source income produced in subsequent
years. Such resulting foreign source income would cover the FTCs being
carried forward. As such, Citi believes the foreign source taxable income
limitation will not be an impediment to the FTC carry-forward usage, as long
as Citi can generate sufficient domestic taxable income within the 10-year
carry-forward period.
As noted in the tables above, Citi’s FTC carry-forwards were $17.6 billion
as of December 31, 2014, compared to $19.6 billion as of December 31,
2013. This decrease represented $2.0 billion of the $3.3 billion decrease in
Citi’s overall DTAs during 2014. Citi believes that it will generate sufficient
U.S. taxable income within the 10-year carry-forward period referenced
above to be able to fully utilize the FTC carry-forward, in addition to
any FTCs produced in such period, which must be used prior to any
carry-forward utilization.