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Income Taxes
12 Months Ended
Dec. 31, 2015
Income Tax Disclosure [Abstract]  
Income Taxes
Income taxes
JPMorgan Chase and its eligible subsidiaries file a consolidated U.S. federal income tax return. JPMorgan Chase uses the asset and liability method to provide income taxes on all transactions recorded in the Consolidated Financial Statements. This method requires that income taxes reflect the expected future tax consequences of temporary differences between the carrying amounts of assets or liabilities for book and tax purposes. Accordingly, a deferred tax asset or liability for each temporary difference is determined based on the tax rates that the Firm expects to be in effect when the underlying items of income and expense are realized. JPMorgan Chase’s expense for income taxes includes the current and deferred portions of that expense. A valuation allowance is established to reduce deferred tax assets to the amount the Firm expects to realize.
Due to the inherent complexities arising from the nature of the Firm’s businesses, and from conducting business and being taxed in a substantial number of jurisdictions, significant judgments and estimates are required to be made. Agreement of tax liabilities between JPMorgan Chase and the many tax jurisdictions in which the Firm files tax returns may not be finalized for several years. Thus, the Firm’s final tax-related assets and liabilities may ultimately be different from those currently reported.
Effective tax rate and expense
A reconciliation of the applicable statutory U.S. income tax rate to the effective tax rate for each of the years ended December 31, 2015, 2014 and 2013, is presented in the following table.
Effective tax rate
 
 
 
 
 
 
Year ended December 31,
 
2015

 
2014

 
2013

Statutory U.S. federal tax rate
 
35.0
 %
 
35.0
 %
 
35.0
 %
Increase/(decrease) in tax rate resulting from:
 
 
 
 
 
 
U.S. state and local income taxes, net of U.S. federal income tax benefit
 
1.5

 
2.7

 
2.2

Tax-exempt income
 
(3.3
)
 
(3.1
)
 
(3.0
)
Non-U.S. subsidiary earnings(a)
 
(3.9
)
 
(2.0
)
 
(4.8
)
Business tax credits
 
(3.7
)
 
(3.3
)
 
(3.4
)
Nondeductible legal expense
 
0.8

 
2.3

 
7.8

Tax audit resolutions
 
(5.7
)
 
(1.4
)
 
(0.6
)
Other, net
 
(0.3
)
 
(1.0
)
 
(0.3
)
Effective tax rate
 
20.4
 %
 
29.2
 %
 
32.9
 %
(a)
Predominantly includes earnings of U.K. subsidiaries that are deemed to be reinvested indefinitely.
The components of income tax expense/(benefit) included in the Consolidated statements of income were as follows for each of the years ended December 31, 2015, 2014, and 2013.
Income tax expense/(benefit)
Year ended December 31,
(in millions)
 
2015

 
2014

 
2013

Current income tax expense/(benefit)
 
 
 
 
 
 
U.S. federal
 
$
3,160

 
$
2,382

 
$
(654
)
Non-U.S.
 
1,220

 
1,353

 
1,308

U.S. state and local
 
547

 
857

 
(4
)
Total current income tax expense/(benefit)
 
4,927

 
4,592

 
650

Deferred income tax expense/(benefit)
 
 
 
 
 
 
U.S. federal
 
1,213

 
3,890

 
7,216

Non-U.S.
 
(95
)
 
71

 
10

U.S. state and local
 
215

 
401

 
913

Total deferred income tax
     expense/(benefit)
 
1,333

 
4,362

 
8,139

Total income tax expense
 
$
6,260

 
$
8,954

 
$
8,789


Total income tax expense includes $2.4 billion, $451 million and $531 million of tax benefits recorded in 2015, 2014, and 2013, respectively, as a result of tax audit resolutions. In 2013, the relationship between current and deferred income tax expense was largely driven by the reversal of significant deferred tax assets as well as prior-year tax adjustments and audit resolutions.
Tax effect of items recorded in stockholders’ equity
The preceding table does not reflect the tax effect of certain items that are recorded each period directly in stockholders’ equity and certain tax benefits associated with the Firm’s employee stock-based compensation plans. The tax effect of all items recorded directly to stockholders’ equity resulted in a increase of $1.5 billion in 2015, a decrease of $140 million in 2014, and an increase of $2.1 billion in 2013.
Results from Non-U.S. earnings
The following table presents the U.S. and non-U.S. components of income before income tax expense for the years ended December 31, 2015, 2014 and 2013.
Year ended December 31,
(in millions)
 
2015

 
2014

 
2013

U.S.
 
$
23,191

 
$
23,422

 
$
17,990

Non-U.S.(a)
 
7,511

 
7,277

 
8,685

Income before income tax expense
 
$
30,702

 
$
30,699

 
$
26,675

(a)
For purposes of this table, non-U.S. income is defined as income generated from operations located outside the U.S.
U.S. federal income taxes have not been provided on the undistributed earnings of certain non-U.S. subsidiaries, to the extent that such earnings have been reinvested abroad for an indefinite period of time. Based on JPMorgan Chase’s ongoing review of the business requirements and capital needs of its non-U.S. subsidiaries, combined with the formation of specific strategies and steps taken to fulfill these requirements and needs, the Firm has determined that the undistributed earnings of certain of its subsidiaries would be indefinitely reinvested to fund current and future growth of the related businesses. As management does not intend to use the earnings of these subsidiaries as a source of funding for its U.S. operations, such earnings will not be distributed to the U.S. in the foreseeable future. For 2015, pretax earnings of $3.5 billion were generated and will be indefinitely reinvested in these subsidiaries. At December 31, 2015, the cumulative amount of undistributed pretax earnings in these subsidiaries were $34.6 billion. If the Firm were to record a deferred tax liability associated with these undistributed earnings, the amount would be $8.2 billion at December 31, 2015.
These undistributed earnings are related to subsidiaries located predominantly in the U.K. where the 2015 statutory tax rate was 20.25%.
Affordable housing tax credits
The Firm recognized $1.6 billion, $1.6 billion and $1.5 billion of tax credits and other tax benefits associated with investments in affordable housing projects within income tax expense for the years 2015, 2014 and 2013, respectively. The amount of amortization of such investments reported in income tax expense under the current period presentation during these years was $1.1 billion, $1.1 billion and $989 million, respectively. The carrying value of these investments, which are reported in other assets on the Firm’s Consolidated balance sheets, was $7.7 billion and $7.3 billion at December 31, 2015 and 2014, respectively. The amount of commitments related to these investments, which are reported in accounts payable and other liabilities on the Firm’s Consolidated balance sheets, was $2.0 billion and $1.8 billion at December 31, 2015 and 2014, respectively.

Deferred taxes
Deferred income tax expense/(benefit) results from differences between assets and liabilities measured for financial reporting purposes versus income tax return purposes. Deferred tax assets are recognized if, in management’s judgment, their realizability is determined to be more likely than not. If a deferred tax asset is determined to be unrealizable, a valuation allowance is established. The significant components of deferred tax assets and liabilities are reflected in the following table as of December 31, 2015 and 2014.
December 31, (in millions)
 
2015

 
2014

Deferred tax assets
 
 
 
 
Allowance for loan losses
 
$
5,343

 
$
5,756

Employee benefits
 
2,972

 
3,378

Accrued expenses and other
 
7,299

 
8,637

Non-U.S. operations
 
5,365

 
5,106

Tax attribute carryforwards
 
2,602

 
570

Gross deferred tax assets
 
23,581

 
23,447

Valuation allowance
 
(735
)
 
(820
)
Deferred tax assets, net of valuation allowance
 
$
22,846

 
$
22,627

Deferred tax liabilities
 
 
 
 
Depreciation and amortization
 
$
3,167

 
$
3,073

Mortgage servicing rights, net of hedges
 
4,968

 
5,533

Leasing transactions
 
3,042

 
2,495

Non-U.S. operations
 
4,285

 
4,444

Other, net
 
4,419

 
5,392

Gross deferred tax liabilities
 
19,881

 
20,937

Net deferred tax assets
 
$
2,965

 
$
1,690

JPMorgan Chase has recorded deferred tax assets of $2.6 billion at December 31, 2015, in connection with U.S. federal, state and local, and non-U.S. net operating loss (“NOL”) carryforwards and foreign tax credit carryforwards. At December 31, 2015, total U.S. federal NOL carryforwards were approximately $5.2 billion, state and local NOL carryforwards were $509 million, and non-U.S. NOL carryforwards were $288 million. If not utilized, the U.S. federal NOLs will expire between 2025 and 2034 and the state and local and non-U.S. NOL carryforwards will expire between 2016 and 2017. Non-U.S. tax credit carryforwards were $704 million and will expire by 2023.
The valuation allowance at December 31, 2015, was due to losses associated with non-U.S. subsidiaries.
Unrecognized tax benefits
At December 31, 2015, 2014 and 2013, JPMorgan Chase’s unrecognized tax benefits, excluding related interest expense and penalties, were $3.5 billion, $4.9 billion and $5.5 billion, respectively, of which $2.1 billion, $3.5 billion and $3.7 billion, respectively, if recognized, would reduce the annual effective tax rate. Included in the amount of unrecognized tax benefits are certain items that would not affect the effective tax rate if they were recognized in the Consolidated statements of income. These unrecognized items include the tax effect of certain temporary differences, the portion of gross state and local unrecognized tax benefits that would be offset by the benefit from associated U.S. federal income tax deductions, and the portion of gross non-U.S. unrecognized tax benefits that would have offsets in other jurisdictions. JPMorgan Chase is presently under audit by a number of taxing authorities, most notably by the Internal Revenue Service as summarized in the Tax examination status table below. As JPMorgan Chase is presently under audit by a number of taxing authorities, it is reasonably possible that over the next 12 months the resolution of these examinations may increase or decrease the gross balance of unrecognized tax benefits by as much as approximately $800 million. Upon settlement of an audit, the change in the unrecognized tax benefit balance would result from payment or income statement recognition.
The following table presents a reconciliation of the beginning and ending amount of unrecognized tax benefits for the years ended December 31, 2015, 2014 and 2013.
Year ended December 31,
(in millions)
 
2015

 
2014

 
2013

Balance at January 1,
 
$
4,911

 
$
5,535

 
$
7,158

Increases based on tax positions related to the current period
 
408

 
810

 
542

Increases based on tax positions related to prior periods
 
1,028

 
477

 
88

Decreases based on tax positions related to prior periods
 
(2,646
)
 
(1,902
)
 
(2,200
)
Decreases related to cash settlements with taxing authorities
 
(204
)
 
(9
)
 
(53
)
Balance at December 31,
 
$
3,497

 
$
4,911

 
$
5,535


After-tax interest expense/(benefit) and penalties related to income tax liabilities recognized in income tax expense were $(156) million, $17 million and $(184) million in 2015, 2014 and 2013, respectively.
At December 31, 2015 and 2014, in addition to the liability for unrecognized tax benefits, the Firm had accrued $578 million and $1.2 billion, respectively, for income tax-related interest and penalties.

Tax examination status
JPMorgan Chase is continually under examination by the Internal Revenue Service, by taxing authorities throughout the world, and by many states throughout the U.S. The following table summarizes the status of significant income tax examinations of JPMorgan Chase and its consolidated subsidiaries as of December 31, 2015.
December 31, 2015
 
Periods under examination
 
Status
JPMorgan Chase – U.S.
 
2003 – 2005
 
Field examination completed; at Appellate level
JPMorgan Chase – U.S.
 
2006 – 2010
 
Field examination completed, JPMorgan Chase filed amended returns and intends to appeal
JPMorgan Chase – U.S.
 
2011 – 2013
 
Field Examination
JPMorgan Chase – New York State
 
2008 – 2011
 
Field Examination
JPMorgan Chase – California
 
2011 – 2012
 
Field Examination
JPMorgan Chase – U.K.
 
2006 – 2012
 
Field examination of certain select entities