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Investor Visas

Itaú Unibanco Sees Common Equity Tier 1 Drop Ahead of Supplementary Law No. 224/2025

Investors receiving Brazilian income face a critical April 15, 2026, U.S. tax deadline. Brazil's new 17.5% withholding rate on equity interest, combined with Itaú Unibanco’s capital ratio fluctuations, necessitates proactive estimated tax management and foreign account reporting to avoid IRS penalties. Key actions include tracking gross versus net payouts and confirming residency status.

Last updated: February 17, 2026 7:13 pm
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Key Takeaways
→U.S. tax residents must pay Q1 estimated taxes by April 15, 2026, for Brazil-source income.
→Brazil’s Law 224/2025 increased withholding rates on Interest on Net Equity from 15% to 17.5%.
→Itaú Unibanco adjusted gross payments to stabilize net shareholder distributions despite new tax burdens.

(BRAZIL) — April 15, 2026 is the next U.S. tax deadline that can hit immigrants and visa holders who receive Brazil-source payouts, including monthly Interest on Capital (IoC) tied to Itaú Unibanco. If you owe U.S. tax on dividends, interest, or similar investment income and don’t have enough withholding, you may need to make a 2026 first-quarter estimated tax payment by April 15, 2026 to reduce underpayment penalties.

This matters now because Brazil’s 2026 reforms change how certain bank payouts are withheld at source, while Itaú’s Common Equity Tier 1 (CET1) ratio has recently weakened. That combination can affect payout design, cash flow timing, and the U.S. tax mechanics for cross-border investors, transferees, and some investor-visa families.

Itaú Unibanco Sees Common Equity Tier 1 Drop Ahead of Supplementary Law No. 224/2025
Itaú Unibanco Sees Common Equity Tier 1 Drop Ahead of Supplementary Law No. 224/2025

📅 Deadline Alert: April 15, 2026 is the due date for Q1 2026 U.S. estimated tax (Form 1040-ES). Missing it can trigger interest and an underpayment penalty (Form 2210).

U.S. deadline summary (what to calendar now)

These dates apply to tax year 2026 cash flows (returns filed in 2027), unless noted.

Tax event Deadline Extension available
Q1 2026 estimated tax (Form 1040-ES) April 15, 2026 No
Q2 2026 estimated tax June 15, 2026 No
Q3 2026 estimated tax September 15, 2026 No
Q4 2026 estimated tax January 15, 2027 No
2026 Form 1040 / 1040-NR filed April 15, 2027 Yes, to October 15, 2027 (Form 4868)
FBAR (FinCEN 114) for 2026 April 15, 2027 Automatic to October 15, 2027
Brazil INE/JCP withholding update (effective 2026)
Law
Supplementary Law No. 224/2025
Effective
January 1, 2026
Change
Withholding income tax on INE/JCP:
15% → 17.5%
→ Analyst Note
If you receive Brazilian bank distributions, separate gross versus net amounts in your records and confirm which withholding rate applied for each payment date. Keep broker statements and issuer notices together so you can reconcile any gross-up adjustments when reporting income in your home country.

IRS international guidance starts at the international taxpayers portal. For residency rules, see Publication 519.

Why Itaú’s capital ratio and Brazil’s 2026 tax changes matter

CET1 is a core bank-capital measure. It compares high-quality capital to risk-weighted assets (RWAs). Investors track CET1 because it can influence loan growth, buffers, and payout capacity.

Brazil’s tax reforms can change net distributable earnings and the tax handling of shareholder remuneration. For immigrants in the U.S., this can change:

  • Your foreign tax credit math (Form 1116) when Brazil withholds more.
  • Estimated tax needs if U.S. tax exceeds withholding.
  • Foreign account reporting if cash accumulates offshore (FBAR, Form 8938).

Itaú Unibanco’s Q4 2025 CET1 performance: what changed

In Q4 2025, Itaú’s CET1 ratio fell meaningfully to a multi-year low. The mechanics were straightforward. CET1 capital fell while RWAs rose, pushing the ratio down.

A quarterly CET1 drop stands out heading into tax and operational reforms. Banks often reassess:

Key Brazil tax reform milestones affecting banks (2025)
Dec 17, 2025
Complementary Bill No. 128/2025 approved (pending presidential sanction)
Jan 1, 2026
INE/JCP withholding increase effective (Supplementary Law No. 224/2025)
Jan 1, 2026
Dual VAT transition begins (CBS + IBS initial phase) and split-payment mechanism starts
2027
CBS moves to full implementation phase
Jan 4, 2027
Itaú’s stated IoC payment schedule runs through this date
2029–2032
IBS transition period
2033
Full VAT transition completion; legacy indirect taxes replaced
  • Capital buffer targets
  • Payout pacing
  • Balance sheet growth

Those decisions can ripple into the timing and form of shareholder distributions received in 2026.

Brazil’s INE/JCP withholding change effective in 2026 (Supplementary Law No. 224/2025)

Supplementary Law No. 224/2025 raised Brazil’s withholding on Interest on Net Equity (INE/JCP) from 15% to 17.5%, effective January 1, 2026.

INE/JCP is a Brazilian form of shareholder remuneration. It is commonly used by banks. Higher withholding generally means less cash received net by the investor, unless the issuer adjusts the gross payment.

For U.S. taxpayers, Brazil withholding can be relevant for the foreign tax credit (Form 1116). It can also affect whether you must pay U.S. estimated tax during the year.

⚠️ Warning: Don’t assume higher Brazil withholding eliminates U.S. tax. U.S. tax rates, credit limits, and filing status can still leave a balance due.

How Itaú adjusted Interest on Capital (IoC) payments in response

Itaú adjusted 2026 monthly IoC payments by raising the gross per-share amount while aiming to keep the net per-share amount stable for many holders. That approach is meant to offset the higher Brazil withholding tied to the 2026 change.

For investors, the key concept is the difference between:

  • Gross per share: the declared amount before withholding.
  • Net per share: what you actually receive after withholding.

Itaú also indicated the schedule extends into early 2027, with the timetable itself described as unchanged. Some corporate or exempt shareholder categories may receive different treatment.

Broader 2026 tax changes affecting banks: incentives, fintech rates, and the new dual VAT

Brazil’s reform package also includes reduced federal incentives over the phase-in period, protections for certain regions, and a directionally higher income tax burden for fintechs. That can shift competition and margins across the financial sector.

The dual VAT transition introduces CBS and IBS test rates starting in 2026, then a multi-year ramp that ultimately replaces legacy indirect taxes. A key operational feature is split payment, where tax is separated during electronic payment flows. Banks may need new controls and reporting, because payment rails can become part of the collection process.

What immigrants, NRIs, and transferees should monitor in 2026

  1. Residency status drives everything. Green card holders and many long-stay visa holders are U.S. tax residents under rules in Pub. 519. Treaty tie-breakers may apply (see IRS tax treaty resources).
  2. Estimated tax risk rises with monthly foreign payouts. Use Form 1040-ES and track withholding and credits.
  3. Foreign reporting can be triggered by routine transfers. If foreign accounts exceed $10,000 aggregate, FBAR applies.
Filing status (living in U.S.) FBAR threshold Form 8938 (end of year) Form 8938 (any time)
Single $10,000 $50,000 $75,000
Married filing jointly $10,000 $100,000 $150,000

Disaster relief can postpone IRS deadlines for certain areas. Check the IRS newsroom for current postponement lists.

Action items for February 2026

  • Confirm whether you must pay Q1 2026 estimated tax by April 15, 2026.
  • Keep Itaú distribution statements showing gross amount, tax withheld, and net received.
  • Track all foreign accounts for FBAR and Form 8938 during 2026.
  • If you recently moved to the U.S. or changed visa status, review residency rules in Publication 519 and consider professional help for dual-status years.

⚠️ Disclaimer: This article is for informational purposes only and does not constitute tax, legal, or financial advice. Tax situations vary based on individual circumstances. Consult a qualified tax professional or CPA for guidance specific to your situation.

Learn Today
CET1
Common Equity Tier 1; a core measure of a bank’s financial strength based on high-quality capital.
INE/JCP
Interest on Net Equity; a Brazilian method of distributing profits to shareholders with tax advantages for the payer.
FBAR
Foreign Bank and Financial Accounts Report; a required disclosure for aggregate foreign holdings over $10,000.
RWA
Risk-Weighted Assets; a bank’s assets weighted according to their risk level to determine capital requirements.
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