EXC · 10-Q · 2026Q3 · Full report
Regulatory Tax Normalization
EXELON CORP · 2026-10-30 · Importance 36 · Surprise 42 · In source text
IRS private letter rulings issued in Q2 2024 to another taxpayer address tax normalization rules for allocating consolidated net operating loss carryforwards (NOLC) in ratemaking. For the Utility Registrants other than PECO, applying the rulings could reduce the regulatory liability for excess deferred income taxes being amortized to customers and reduce accumulated deferred income taxes included in rate base by approximately $0.8 billion to $1.2 billion. The affected Utility Registrants have requested their own IRS rulings and will record any impact after receiving a response.
Key facts
- For utility registrants other than PECO, the IRS-prescribed NOLC ratemaking methodology could reduce the regulatory liability for EDITs and accumulated deferred income taxes included in rate base by approximately $0.8 billion to $1.2 billion.
- Utility registrants other than PECO filed IRS private letter ruling requests concerning NOLC treatment for ratemaking, and will record any impact upon receiving the IRS ruling.
Impact estimates
| metric | direction | stage | expected | basis |
|---|---|---|---|---|
| liability | positive | contingent | +0.1% | For utility registrants other than PECO, the IRS-prescribed NOLC ratemaking methodology could reduce the regulatory liability for EDITs… |