IRS Files Lawsuit Against FDIC Over Silicon Valley Bank’s $1.4B Tax Debt Dispute

Feb 13, 2024

IRS Files Lawsuit Against FDIC Over Silicon Valley Bank’s $1.4B Tax Debt Dispute

Background

The U.S. Internal Revenue Service (IRS) has filed a lawsuit against the Federal Deposit Insurance Corporation (FDIC) over a $1.4 billion tax debt dispute related to the failed Silicon Valley Bank (SVB). SVB, based in Santa Clara, California, became one of the largest bank failures in U.S. history when it collapsed in March 2023. The FDIC seized SVB and its assets but has denied the entire tax claim made by the IRS.

The Lawsuit

The IRS is seeking a judge’s determination on how much the FDIC must pay to cover the estimated $1.45 billion tax debt owed by SVB. In its complaint filed in federal court in Washington, the IRS argues that the court should overrule the FDIC’s decision to deny the tax claim and make a new determination on the validity and amount of taxes owed.

IRS Claim and Review

The IRS initially claimed $1.45 billion as an estimated total for taxes due between 2020 and 2023. However, the IRS later discovered that some of the employment taxes included in the claim had already been paid. The IRS is still reviewing SVB’s tax returns, which were incomplete when the claim was filed.

FDIC Response

The FDIC, acting as a receiver for SVB, is responsible for gathering the bank’s assets and using them to repay the bank’s creditors. The FDIC has denied the tax claim made by the IRS over the Silicon Valley Bank’s tax debt. The FDIC has not yet responded to the lawsuit or provided any comments on the ongoing dispute.

SVB Financial Lawsuit

In addition to the IRS lawsuit, SVB Financial, the former parent company of Silicon Valley Bank, has also sued the FDIC over its seizure of $1.93 billion in cash during the bank’s takeover. SVB Financial filed for bankruptcy after SVB’s collapse and claims that the FDIC should repay the cash held in the parent company’s accounts. SVB Financial argues that the FDIC had promised to fully backstop all deposits at the bank, even those exceeding the $250,000 guaranteed by U.S. law. The FDIC disagrees and maintains that SVB Financial’s cash can be seized to cover the cost of bailing out the failed bank.

Impact on the Banking Industry

The collapse of Silicon Valley Bank and the subsequent disputes between the IRS, FDIC, and SVB Financial have sent shockwaves through the regional banking industry in the U.S. Many tech startups that had their funds deposited in SVB experienced disruptions due to the bank’s failure. The outcome of these lawsuits could have far-reaching implications for the banking sector and how tax debts are handled in the event of bank failures.

Frequently Asked Questions (FAQs)

1. What is the lawsuit about?

The IRS has filed a lawsuit against the FDIC over a $1.4 billion tax debt dispute related to the failed Silicon Valley Bank. The IRS is seeking a determination of the amount the FDIC must pay to cover the tax debt.

2. Why did the IRS file the lawsuit?

The IRS believes that the FDIC’s denial of the tax claim made by the IRS is unjust and wants the court to overrule the denial and determine the validity and amount of taxes owed.

3. What is SVB Financial’s lawsuit about?

SVB Financial, the former parent company of Silicon Valley Bank, has sued the FDIC over the seizure of $1.93 billion in cash during the bank’s takeover. SVB Financial claims that the FDIC should repay the cash held in its accounts.

4. What impact does this have on the banking industry?

The collapse of Silicon Valley Bank and the ongoing disputes between the IRS, FDIC, and SVB Financial have caused disruptions in the regional banking industry. The outcome of these lawsuits could have significant implications for how tax debts are handled in the event of bank failures.

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