Norwest Corporation and Subsidiaries - Page 5

            among those members that had taxable income for the year.  This                           
            allocation was based on the ratio that each member's regular tax                          

                        Sec. 1552(a)(2) provides:                                                     
                        The tax liability of the group shall be                                       
                        allocated to the several members of the group                                 
                        on the basis of the percentage of the total                                   
                        tax which the tax of such member if computed                                  
                        on a separate return would bear to the total                                  
                        amount of the taxes for all members of the                                    
                        group so computed.                                                            
                        Sec. 1.1502-33(d)(2)(ii), Income Tax Regs., provides:                         
                              (ii)(a) The tax liability of the group,                                 
                        as determined under paragraph (b)(1) of sec.                                  
                        1.1552-1, shall be allocated to the members                                   
                        in accordance with paragraph (a)(1), (2), or                                  
                        (3) of sec. 1.1552-1, whichever is                                            
                              (b) An additional amount shall be                                       
                        allocated to each member equal to a fixed                                     
                        percentage (which does not exceed 100                                         
                        percent) of the excess, if any, of (1) the                                    
                        separate return tax liability of such member                                  
                        for the taxable year (computed as provided in                                 
                        paragraph (a)(2)(ii) of sec. 1.1552-1), over                                  
                        (2) the tax liability allocated to such                                       
                        member in accordance with (a) of this                                         
                        subdivision (ii); and                                                         
                                    (c) The total of any additional                                   
                        amounts allocated pursuant to (b) of this                                     
                        subdivision (ii) (including amounts allocated                                 
                        as a result of a carryback) shall be credited                                 
                        to the earnings and profits of those members                                  
                        which had items of income, deductions, or                                     
                        credits to which such total is attributable                                   
                        pursuant to a consistent method which fairly                                  
                        reflects such items of income, deductions, or                                 
                        credits, and which is substantiated by                                        
                        specific records maintained by the group for                                  
                        such purpose.                                                                 

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Last modified: May 25, 2011