IRS Issues Guidance on Tax Treatment of the FDIC Three-Year Prepaid Assessment

When the Federal Deposit Insurance Corporation (FDIC) issued a final rule in 2009 requiring financial institutions to prepay their estimated quarterly assessments for the fourth quarter of 2009 and all of 2010 through 2012, questions understandably arose about the proper tax treatment of the prepayments – specifically, whether the “12-month rule” would apply to allow accelerated deduction of the prepayments.