v3.25.2
Income Taxes
 6 Months Ended
Jun. 30, 2025
Income Tax Disclosure [Abstract]  
Income Taxes Income Taxes
Rate Reconciliation
The effective income tax rate varies from the U.S. federal statutory rate principally due to the following:
Three Months Ended June 30,
2025
2024
U.S. federal statutory income tax21.0 %$267 21.0 %$202 
(Decrease) increase due to:
State income taxes, net of federal income tax benefit(a)
3.8 48 2.5 24 
Foreign tax effects
— — 0.1 1 
Tax credits
PTC(0.9)(11)(8.9)(86)
Amortization of ITC, including deferred taxes on basis differences(0.2)(3)(0.2)(2)
Other(0.2)(3)(0.7)(7)
Nontaxable or nondeductible items
Share-based payment awards(0.1)(1)— — 
Excess officers compensation0.7 9 0.5 5 
Other— — 0.4 4 
Other adjustments
Qualified NDT fund income and losses10.5 134 1.3 13 
Effective income tax34.6 %$440 16.0 %$154 
Six Months Ended June 30,
2025
2024
U.S. federal statutory income tax
21.0 %$299 21.0 %$422 
(Decrease) increase due to:
State income taxes, net of federal income tax benefit(a)
3.3 47 (2.0)(40)
Foreign tax effects
0.1 1 0.1 2 
Tax credits
PTC
(0.9)(13)(7.4)(149)
Amortization of ITC, including deferred taxes on basis differences(0.4)(5)(0.2)(4)
Other(0.4)(5)(0.7)(14)
Nontaxable or nondeductible items
Share-based payment awards(2.8)(40)(0.8)(16)
Excess officers compensation1.1 16 0.4 8 
Other— — 0.1 2 
Other adjustments
Qualified NDT fund income and losses
11.4 162 5.3 107 
Effective income tax
32.4 %$462 15.8 %$318 
__________
(a)State taxes in California, Illinois, Maryland, Massachusetts, and New Jersey made up the majority (greater than 50%) of the tax effect in this category.
Other Tax Matters
One Big Beautiful Bill Act
In July 2025, Congress passed the OBBBA which among other things included certain changes in tax law. See Note 17 — Subsequent Events for additional information.
Tax Matters Agreement
In connection with the separation, we entered a TMA with Exelon. The TMA governs the respective rights, responsibilities, and obligations between us and Exelon after the separation with respect to tax liabilities and benefits, tax attributes, tax returns, tax contests and other tax sharing regarding U.S. federal, state, local and foreign income taxes, other tax matters and related tax returns.
Responsibility and Indemnification for Taxes. As a former subsidiary of Exelon, we have joint and several liability with Exelon to the IRS and certain state jurisdictions relating to the taxable periods in which we were included in joint federal and state filings. However, the TMA specifies the portion of this tax liability for which we will bear contractual responsibility, and we and Exelon agreed to indemnify each other against any amounts for which such indemnified party is not responsible. Specifically, we will be liable for taxes due and payable in connection with tax returns that we are required to file. We will also be liable for our share of certain taxes required to be paid by Exelon with respect to taxable years or periods (or portions thereof) ending on or prior to the separation to the extent that we would have been responsible for such taxes under the Exelon tax sharing agreement then existing. As of June 30, 2025 and December 31, 2024, respectively, our Consolidated Balance Sheets reflect $42 million and $39 million in Other deferred credits and other liabilities, for tax liabilities where we maintain contractual responsibility to Exelon.
Tax Refunds and Attributes. The TMA provides for the allocation of certain pre-closing tax attributes between us and Exelon. Tax attributes will be allocated in accordance with the principles set forth in the existing Exelon tax sharing agreement, unless otherwise required by law. Under the TMA, we will be entitled to refunds for taxes for which we are responsible. In addition, it is expected that Exelon will have tax attributes that may be used to offset Exelon’s future tax liabilities. A significant portion of such attributes were generated by our business. In February 2024, we executed an amendment to the TMA that modified the timing of Exelon's payment of amounts due to us. During the second quarter of 2025 and 2024, we received payments for tax attributes utilized by Exelon related to the 2024 and 2023 tax years of $127 million and $183 million, respectively. As of June 30, 2025 and December 31, 2024, respectively, we had $174 million and $138 million in Other accounts receivable and $38 million and $201 million in Other deferred debits and other assets for the reclassified tax attributes expected to be utilized by Exelon after separation in accordance with the terms of the TMA.