AMGN · 10-Q · 2026Q2 · Full report

IRS Tax Examinations

AMGEN INC · 2026-08-05 · Importance 53 · Surprise 60 · In source text

The IRS is examining Amgen’s tax years 2016–2018 and issued substantially similar draft notices of proposed adjustment in April, May and July 2026. The proposed adjustments concern profit allocation between the United States and Puerto Rico and could materially affect Amgen’s financial statements if sustained in full. The IRS began auditing 2019–2022 in the second quarter of 2026 and may pursue similar income-allocation issues involving foreign jurisdictions. Amgen expects ultimate tax outcomes could require payments substantially greater than accrued amounts.

Key facts

• The IRS Notices for years 2010–2012 seek additional federal tax of approximately $3.6 billion, plus interest source
• The IRS Notice for years 2013–2015 seeks additional federal tax of approximately $5.1 billion, plus interest, and asserts penalties of approximately $2.0 billion source
• We are currently under examination by the IRS for the years 2016–2018 and in April 2026 received a draft notice of proposed adjustment (NOPA) for years 2016–2018 which was reissued in May and July 2026. source
• The IRS began its audit for years 2019–2022 in the second quarter of 2026. source
• In April 2026 the Company received a draft notice of proposed adjustment (NOPA) from the IRS for years 2016–2018 and the IRS reissued the NOPA in May and July 2026 source
• If sustained in full, the adjustments set forth in the NOPA for 2016–2018 could have a material impact on our financial statements source
• If sustained in full, the adjustments set forth in the NOPA for 2016–2018 could have a material impact on our financial statements and we intend to contest the NOPA. source
• During the three and six months ended June 30, 2026, the gross amounts of our UTBs increased by $ million and $ million, respectively (amounts redacted in filing) source

Impact estimates