v3.25.4
INCOME TAXES (Tables)
12 Months Ended
Dec. 31, 2025
Income Tax Disclosure [Abstract]  
Schedule of Provision/(Benefit) for Income Taxes
The provision/(benefit) for income taxes consisted of:
Year Ended December 31,
Dollars in millions202520242023
Current:
U.S.(a)
$1,699 $1,279 $2,745 
Non-U.S.1,538 1,364 943 
Total current3,237 2,643 3,688 
Deferred:
U.S.(a)
(1,107)(2,185)(2,339)
Non-U.S.142 96 (949)
Total deferred(965)(2,089)(3,288)
 Income tax provision
$2,272 $554 $400 
(a)    The Company's 2025 U.S. income tax provision reflects federal current tax expense of $1.5 billion and federal deferred tax benefit of $1.0 billion as well as the impact of U.S. state taxes.
Schedule of Effective Income Tax Rate Reconciliation
The reconciliation of the effective tax rate to the U.S. statutory Federal income tax rate in 2025 was as follows:
% of Earnings Before Income Taxes
Dollars in millions2025
Earnings/(Loss) before income taxes:
U.S.$(19)
Non-U.S.9,347 
Total9,328 
U.S. Federal statutory rate
1,959 21.0 %
Effects of cross-border tax laws:
GILTI
228 2.4 %
FDII deduction
(170)(1.8)%
Foreign tax effects:
Switzerland
Statutory tax rate difference between Switzerland and the U.S.(565)(6.1)%
Canton
284 3.0 %
Pillar Two
24 0.3 %
Withholding Tax
87 0.9 %
Other
(11)(0.1)%
Ireland
Statutory tax rate difference between Ireland and the U.S.(390)(4.2)%
Pillar Two
37 0.4 %
Other
— %
Other foreign jurisdictions
129 1.4 %
U.S. Federal research-based credits
(152)(1.6)%
Changes in valuation allowances
84 0.9 %
Nondeductible R&D charges290 3.1 %
Changes in unrecognized tax benefits
146 1.6 %
State and local taxes
43 0.5 %
Other adjustments
247 2.7 %
Income tax provision
$2,272 24.4 %
The reconciliation of the effective tax rate to the U.S. statutory Federal income tax rate in 2024 and 2023 were as follows:

% of Earnings Before Income Taxes
Dollars in millions20242023
Earnings/(Loss) before income taxes:
U.S.$(14,893)$2,624 
Non-U.S.6,514 5,816 
Total(8,379)8,440 
U.S. Federal statutory rate
(1,759)21.0 %1,772 21.0 %
Nondeductible R&D charges
2,538 (30.3)%— — %
GILTI, net of foreign derived intangible income deduction 501 (6.0)%223 2.6 %
Foreign tax effect of certain operations in Ireland, Puerto Rico and Switzerland(302)3.6 %(850)(10.1)%
Non-U.S. tax ruling
— — %(656)(7.8)%
U.S. Federal valuation allowance
46 (0.5)%(171)(2.0)%
U.S. Federal, state and foreign contingent tax matters(459)5.5 %143 1.7 %
U.S. Federal research-based credits(291)3.5 %(243)(2.9)%
Charitable contributions of inventory(36)0.4 %(75)(0.9)%
State and local taxes (net of valuation allowance)(25)0.3 %92 1.1 %
Foreign and other341 (4.1)%165 2.0 %
Income tax provision
$554 (6.6)%$400 4.7 %
Schedule of Deferred Income Tax Assets/(Liabilities)
The components of deferred income tax assets/(liabilities) were as follows:
 December 31,
Dollars in millions20252024
Deferred tax assets
Foreign net operating loss and other carryforwards$1,229 $1,521 
State net operating loss and credit carryforwards629 529 
U.S. Federal capital loss, net operating loss and tax credit
557 695 
Milestone payments and license fees1,330 999 
Capitalized research expenditures4,366 3,886 
Other1,771 1,738 
Total deferred tax assets9,882 9,368 
Valuation allowance(960)(929)
Deferred tax assets net of valuation allowance$8,922 $8,439 
Deferred tax liabilities
Acquired intangible assets$(3,069)$(3,781)
Goodwill and other(698)(791)
Total deferred tax liabilities$(3,767)$(4,572)
Deferred tax assets/(liabilities), net
$5,155 $3,867 
Recognized as:
Deferred income taxes assets – non-current$5,378 $4,236 
Deferred income taxes liabilities – non-current(222)(369)
Total$5,155 $3,867 
Changes in the Valuation Allowance
Changes in the valuation allowance were as follows:
 Year Ended December 31,
Dollars in millions202520242023
Beginning balance
$929 $764 $873 
Provision231 242 (39)
Utilization(108)(182)(54)
Foreign currency translation14 (9)(19)
Acquisitions/(dispositions)/(liquidations), net(109)113 — 
Non-U.S. tax rate change
Ending balance
$960 $929 $764 
Schedule of Income Tax Payments
Income tax payments in 2025 were as follows:

 Year Ended December 31,
Dollars in millions2025
Federal
$2,199 
State
207 
Foreign
Switzerland
298 
Ireland
179 
Other foreign
381 
Income tax payments
$3,264 
Reconciliation of Gross Unrecognized Tax Benefits
A reconciliation of the beginning and ending amount of gross unrecognized tax benefits is as follows (excluding interest and penalties):
 Year Ended December 31,
Dollars in millions202520242023
Beginning balance
$1,428 $1,914 $1,766 
Gross additions to tax positions related to current year73 68 38 
Gross additions to tax positions related to prior years(a)
269 64 145 
Gross additions to tax positions assumed in acquisitions12 113 — 
Gross reductions to tax positions related to prior years(55)(670)(5)
Settlements(18)(50)(30)
Reductions to tax positions related to lapse of statute(b)
(239)(3)(4)
Cumulative translation adjustment13 (8)
Ending balance$1,483 $1,428 $1,914 
(a)    Amounts in 2025 include certain transfer pricing and other matters.
(b)    Amounts in 2025 primarily relate to the lapse of statute for the U.S. federal years 2019-2020.
Summary of Income Tax Examinations
Additional information regarding unrecognized tax benefits is as follows:
 Year Ended December 31,
Dollars in millions202520242023
Unrecognized tax benefits that if recognized would impact the effective tax rate$1,356 $1,394 $1,872 
Accrued interest536 507 434 
Accrued penalties23 19 23 
Interest and penalties expense/(benefit)209 89 110 
The following is a summary of major tax jurisdictions for which tax authorities may assert additional taxes based upon tax years currently under audit and subsequent years that are subject to audit:
Jurisdictions
Tax Years
U.S.
2008 to 2012, 2016 to 2018, 2021 to 2025
Canada2012 to 2025
France
2022 to 2025
Germany2015 to 2025
Italy
2019 to 2025
Japan2023 to 2025
UK
2017 to 2025