By Bob Davis

WASHINGTON—The U.S. and European governments are moving toward a consensus on taxing large banks to cover the cost of any future bailouts rather than asking taxpayers to foot the bill, as happened regularly in past banking crises.

The tax proposals vary. Germany and Sweden would use the money to fund a "resolution authority" that would use the money to shut troubled banks whose failure would put the broader economy at risk. Others, such as France, would assess the fee after a crisis passed.

The U.S. is split. Congress is moving toward imposing a levy to build a fund before a crisis. The Obama administration favors the post-crisis option, a difference that will be worked out as financial-regulation legislation moves through Congress.

The proposals face opposition from banks, who argue that the levies are discriminatory and would limit their capacity to lend. "Global policy makers should be very cautious about advancing any public policy that removes capital from the system—be it in the form of a tax, a fee or otherwise," said Rob Nichols, president of the Financial Services Forum, a trade association of large U.S. financial institutions.

The possible bank taxes are part of a wave of potential bank regulations on tap in the coming months. In the U.S., now that health-care legislation is effectively complete, Congress and the administration are turning to financial regulation, which would create a consumer-finance-protection agency, and also enact rules limiting the businesses in which banks can operate and the levels of capital they must hold. Similar efforts are under way in Europe, where the International Monetary Fund is proposing a resolution agency for the European Union.

Officials in the U.S., Europe and the IMF say the bank-tax concept has gained so much momentum that it is likely to be on the agenda when of the Group of 20 industrial and developing nations meet in Canada in June. "Reforms would put in practice the principle that large institutions should bear the costs of any losses to the taxpayer," U.S. Treasury Secretary Timothy Geithner said in a speech last week.

French Finance Minister Christine Lagarde called a bank tax "an interesting concept which can take several forms" in an interview earlier this month with French newspaper "Les Echos."

In the U.S., the House and the Senate banking committees have approved proposals to assess banks in advance to finance future rescues. The Obama administration prefers to impose a levy after a crisis, arguing that establishing a fund in advance could encourage bankers to take too much risk because the fund could become a way to finance troubled banks, rather than shut them down.

The administration's proposal would use a temporary government loan to handle crises and then recoup the money from banks later after a crisis. To recoup payments for the recent crisis, the Treasury has proposed a "financial crisis responsibility fee" on the short-term liabilities of banks with assets of more than $50 billion.

In the U.K., Prime Minister Gordon Brown has been championing a global levy, including one in which revenues would be used to help pay down deficits, though will only press ahead if there is an international consensus. The opposition Conservative Party says it will press ahead regardless, though the fee's size will depend on how far other countries follow

The U.S. and U.K., which have a similar approach to markets and business, often see eye-to-eye on banking regulation. But a number of countries in continental Europe are also backing the idea. Sweden last year put in place a "stability fee," that requires banks to pay levies into a fund that is eventually expected to grow to 2.5% of gross domestic product. German Chancellor Angela Merkel backs a similar fee and plans to present a plan to her cabinet for approval on Wednesday. She views the levies as part of new financial regulations that she wants taken up by the G-20, said a government spokesman.

The IMF plans to recommend a bank tax when global economic officials convene in Washington in April and is leaning toward a fee in advance to fund a resolution authority, said officials involved with the IMF effort. That recommendation is likely to be influential with other countries.

Support for a bank tax isn't unanimous among the G-20. Canada, which now has an outsized role in the group's deliberations because it hosts this year's meeting, opposes a tax on its banks.

"We are rejecting it out of hand," said Canadian Finance Minister Jim Flaherty.

Instead, Canada, whose banks weathered the crisis well, is pressing the G-20 to stiffen leverage requirements to avert problems, a proposal that has already been on the group's agenda. India and China haven't taken firm positions.

In past banking crises in Sweden, Britain, the U.S. and Asia, taxpayers picked up the cost of bailing out troubled institutions because the government had to act quickly to contain the problem and the banks had been so battered they couldn't repay the money.

But both the politics and economics have changed in the past two years in the U.S. and Europe, where a banking crisis provoked the deepest recession since the Great Depression. Populist anger is rising over the costs of the bailout, and major banks have recovered so quickly that they have profits that can be taxed.

—Alistair MacDonald and Patrick McGroarty contributed to this article.