You are right, there is. Since it would be silly for the government to tax itself, the pro rata part of Citi that will be owned by the "government" - after the conversion of debt into shares - will not be taxed on its profits, thus "giving up billions in tax money", in WaPo vernacular.
US Forgoes Billions in Tax on Citi - CNBC staff and wire reports, 2009 December 15 The Internal Revenue Service issued a notice on Friday that extends the benefit to Citi and other companies in which the government owns a stake, the Post reported. A Citigroup spokesman declined to comment. The Washington Post said the precise value of the IRS ruling depends on Citigroup's future profitability and other factors, but the newspaper cited two accounting experts as estimating Citi would save at least several billion dollars. A Treasury spokesperson told CNBC: "This rule was designed to stop corporate raiders from using shell losses to evade taxes, and was never intended to address the unprecedented situation where the government owned share in banks." At the end of the third quarter, Citi said its past losses were valued at about $38 billion, allowing it to avoid taxes on its next $38 billion in profits, but under normal IRS rules, a change in control would have sharply reduced the amount the company could shelter from taxes, the newspaper said. Under a deal announced Monday, Citi will sell $17 billion of common stock and about $3.5 billion of securities that turn into common shares in three years, helping the bank repay the bailout. The government will also stop guaranteeing a pool of toxic assets against excessive losses, and will sell the nearly $30 billion in shares it owns. The U.S. government "quietly" agreed not to collect billions of dollars in potential taxes from Citigroup as part of its deal to allow the bank to repay its taxpayer bailout, The Washington Post reported.
"This rule was designed to stop corporate raiders from using shell losses to evade taxes, and was never intended to address the unprecedented situation where the government owned share in banks."
... under normal IRS rules, a change in control would have sharply reduced the amount the company could shelter from taxes.
The treasury is going to make money, net, on all of its dealings with Citigroup. It has not lost a dime to date and it isn't going to. Magical mystery accounting of fantasy wealth Citi was supposed to pay the treasury if trees grew to the sky are not "revenue". Investment in Citi stock, preferred or common, are not "losses".
But everyone wants to hate these people, so they make up any lie they can at the precise moment their thesis is collapsing, because the treasury is being repaid by private money.
It is sickening that people pretending to be conservatives are in any way connected with this. It is all transparent lies and slander, start to finish. Ask any of them to state the amount that the US treasury has lost on TARP for banks, or Citi specifically. They can't, they are practicing not even one entry accounting, but pure make believe accounting.