Wells Fargo & Company (f.k.a. Norwest Corporation) and Subsidiaries - Page 52




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            1992-94.  In our opinion, Mr. Daskais’s after-tax rates are too                             
            high because they do not take into account the Minnesota State tax                          
            on unrelated business income.  Minnesota taxes the unrelated income                         
            of an exempt organization at the corporate rate of 9.8 percent.                             
            Minn. Stat. Ann. secs. 290.05, subd. 3, and 290.06, subd. 1 (West                           
            1999 & Supp. 2003).  Since State taxes paid are deducted for                                
            purposes of Federal tax, the combined tax rate would be 36 percent23                        
            for 1991-92 and 38.6 percent24 for 1993-94.  Applying the combined                          
            tax rates to the pretax investment rates Mr. Daskais considers                              
            reasonable results in the following after-tax investment rates                              
            (rounded to nearest tenth of a percent):                                                    
                                          1991    1992    1993    1994                                  
                  Pretax rate             9.0%    8.0%    8.0%    7.0%                                  
                  After-tax rate                5.8     5.1     4.9     4.3                             


                  23    The combined tax rate for 1991-92 is computed as follows:                       
                        Starting point                          100.0%                                  
                        Minn. State tax at 9.8% (100 x 9.8%)    - 9.8                                   
                        90.2                                                                            
                        Federal tax at 29% (90.2 x 29%)         -26.2                                   
                        64.0                                                                            
                                                                                                       
                        Combined tax rate (100% - 64%)           36                                     

                  24    The combined tax rate for 1993-94 is computed as follows:                       
                        Starting point                          100.0 %                                 
                        Minn. State tax at 9.8% (100 x 9.8%)    - 9.8                                   
                        90.2                                                                            
                        Federal tax at 31.9% (90.2 x 31.9%)     -28.8                                   
                        61.4                                                                            
                                                                                                       
                        Combined tax rate (100% - 61.4%)         38.6                                   




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Last modified: May 25, 2011