Mizuho Financial Group, Inc. ("MHFG") hereby announces that the Supreme Court rendered today its judgment on the petition of Mizuho Corporate Bank, Ltd. ("MHCB"), a wholly-owned subsidiary of MHFG, for rescission of a corporate tax correction regarding MHCB's write-off of credits against Japan Housing Loan, Inc.
1. Background of the Facts
March 1996 | The Industrial Bank of Japan, Limited ("IBJ", later succeeded by MHCB) deducted loss in its tax return for the Fiscal 1995 from its write-off of credits against Japan Housing Loan, Inc. in an amount of JPY 376 billion. |
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August 23, 1996 | IBJ received a notice of corporate tax correction from the Director of the Kojimachi Tax Office. |
August 27, 1996 | According to the correction notice, IBJ provisionally made an additional tax payment of JPY 222.6 billion. |
August 30, 1996 | IBJ disagreed with the correction and filed a petition requesting the National Tax Tribunal to reexamine the correction. |
October 27, 1997 | The National Tax Tribunal dismissed IBJ's petition for reexamination. |
October 30, 1997 | IBJ filed a lawsuit in the Tokyo District Court. |
March 2, 2001 | The Tokyo District Court ruled in favor of IBJ. |
March 16, 2001 | The Director of the Kojimachi Tax Office appealed to the Tokyo High Court. |
March 14, 2002 | The Tokyo High Court ruled against IBJ. |
March 27, 2002 | IBJ appealed to the Supreme Court and filed a motion for acceptance of appeal. |
April 26, 2002 | MHCB took over the case as the successor to IBJ. |
October 28, 2004 | The Supreme Court decided to hear arguments on the case. |
December 6, 2004 | The relevant parties made oral arguments at the Supreme Court. |
December 24, 2004 | The Supreme Court rendered its judgment. |
2. Details of the Facts
The Supreme Court ruled in favor of MHCB, supporting MHCB's petition for rescission. As a result, the additional tax payment of JPY 222.6 billion provisionally made in 1996 will be refunded to MHCB.
3. Effect on the Profit and Loss Statements
The effect on the profit and loss statement of MHFG on a consolidated basis is expected to be around JPY 280 billion. This effect is composed of the reversal of Reserve for Contingencies, the receipt of interest attached to the refund of provisional tax payment, and the decrease in Valuation Allowance for Deferred Tax Assets.
The revision of MHFG's previously announced Earnings Estimates for the Fiscal 2004 will be announced on December 27, 2004 after reviewing the financial effect of this judgment.