AMGN · 10-Q · 2026Q3 · Full report

IRS Tax Examinations

AMGEN INC · 2026-11-04 · Importance 47 · Surprise 60 · In source text

The IRS is examining Amgen’s 2016–2018 tax years and issued draft proposed adjustments in April 2026, reissued in May and July, concerning allocation of profits between U.S. entities and the U.S. territory of Puerto Rico. In September 2026, the IRS also proposed penalties substantially similar to those asserted for 2013–2015; if sustained in full, the adjustments and penalties could materially affect Amgen’s financial statements. The IRS began its audit of 2019–2022 in the second quarter of 2026, and Amgen believes similar income-allocation issues may be examined. Amgen intends to contest the proposed adjustments and penalties.

Key facts

• In September 2026, Amgen received a draft IRS NOPA asserting penalties for 2016–2018 substantially similar to those asserted for 2013–2015; if sustained in full, the proposed adjustments and penalties could materially affect Amgen's financial statements. source
• Amgen is under IRS examination for tax years 2016–2018; in April 2026 it received a draft NOPA concerning profit allocation between U.S. entities and Puerto Rico entities, and the IRS reissued it in substantially the same form in May and July 2026. source
• The IRS began its audit of Amgen for years 2019–2022 in the second quarter of 2026, and Amgen believes the IRS may examine similar income-allocation issues involving the United States and foreign jurisdictions. source
• Amgen says final resolution of its complex tax matters is not likely within the next 12 months; payments could ultimately be substantially greater than accrued amounts and materially adversely affect its financial statements. source
• In September 2026, Amgen received a draft IRS notice asserting penalties for 2016–2018 substantially similar to those asserted for 2013–2015; if sustained in full, the proposed adjustments and penalties could materially affect Amgen's financial statements. source
• Amgen is under IRS examination for 2016–2018; the IRS issued draft proposed adjustments in April 2026 and reissued them in May and July 2026 in substantially the same form, concerning allocation of profits between U.S. entities and Puerto Rico. source
• The IRS began auditing Amgen's 2019–2022 tax years in the second quarter of 2026 and may pursue similar income-allocation issues involving the United States and foreign jurisdictions. source
• Amgen disagrees with the proposed 2016–2018 IRS adjustments and penalties and intends to contest them. source

Impact estimates