INCOME TAXES

See Note 5 to the financial statements of each registrant in Item 8 of the Form 10-K for additional tax information.

Current and Deferred Income Taxes

Net Operating Loss

Southern Company expects to be in a consolidated net operating loss (NOL) position for income tax purposes for the 2016 tax year. The NOL will limit the amount of positive cash flows resulting from bonus depreciation, ITCs, and PTCs for the tax year and will significantly increase deferred tax assets for the NOL and tax credit carryforwards. Portions of the NOL are expected to be carried back to prior tax years and forward to the 2017 tax year, which could further increase existing tax credit carryforwards. The ultimate outcome of this matter cannot be determined at this time.

Tax Credit Carryforwards

Southern Company had federal ITC and PTC carryforwards (primarily related to Southern Power) totaling $1.2 billion and $26 million, respectively, as of September 30, 2016 and $554 million and $1 million, respectively, as of December 31, 2015. Additionally, Southern Company had $165 million of state ITC carryforwards for the state of Georgia as of September 30, 2016 compared to $188 million as of December 31, 2015. See "Unrecognized Tax Benefits" herein for further information.

The federal ITC carryforwards as of September 30, 2016 begin expiring in 2034 but are expected to be utilized by the end of 2021. The PTC carryforwards as of September 30, 2016 begin expiring in 2035 but are expected to be utilized by the end of 2021. The state ITC carryforwards for the state of Georgia as of September 30, 2016 expire between 2020 and 2026 but are expected to be fully utilized by the end of 2022.

Effective Tax Rate

Southern Company

Southern Company's effective tax rate is typically lower than the statutory rate due to employee stock plans' dividend deduction, non-taxable AFUDC equity, and federal income tax benefits from ITCs and PTCs.

Southern Company's effective tax rate was 29.1% for the nine months ended September 30, 2016 compared to 33.5% for the corresponding period in 2015. The effective tax rate decrease was primarily due to increased federal income tax benefits from ITCs and PTCs at Southern Power, partially offset by the impact of additional state income tax benefits recognized in 2015.

Mississippi Power

Mississippi Power's effective tax (benefit) rate was (276.2)% for the nine months ended September 30, 2016 compared to (20.9)% for the corresponding period in 2015. The effective tax rate decrease was primarily due to an increase in tax benefits related to the estimated probable losses on construction of the Kemper IGCC and an increase in non-taxable AFUDC equity.

Southern Power

Southern Power's effective tax (benefit) rate was (88.9)% for the nine months ended September 30, 2016 compared to 6.9% for the corresponding period in 2015. The effective tax rate decrease was primarily due to increased federal income tax benefits from ITCs related to solar projects expected to be placed in service in 2016 and additional PTCs related to wind projects in 2016 compared to 2015.

Unrecognized Tax Benefits

See Note 5 to the financial statements of each registrant under "Unrecognized Tax Benefits" in Item 8 of the Form 10-K for additional information.

Changes during 2016 for unrecognized tax benefits were as follows:



	Mississippi Power		Southern Power			Southern Company
	(in millions)
Unrecognized tax benefits as of December 31, 2015	$	421	$	8		$	433
Tax positions from current periods	—		12			12
Tax positions from prior periods	18		(1		)	13
Balance as of September 30, 2016	$	439	$	19		$	458

The tax positions from current periods primarily relate to federal income tax benefits from deferred ITCs and ITCs impacting the estimated annual effective tax rate for interim reporting purposes. The tax positions from prior periods primarily relate to federal income tax benefits from ITCs, and from deductions for Kemper IGCC-related research and experimental (R&E) expenditures. See "Section 174 Research and Experimental Deduction" below for additional information. These amounts are presented on a gross basis without considering the related federal or state income tax impact.

The impact on the effective tax rate, if recognized, is as follows:



	As of September 30, 2016						As of December 31, 2015
	Mississippi Power		Southern Power		Southern Company		Southern Company
	(in millions)
Tax positions impacting the effective tax rate	$	1	$	19	$	20	$	10
Tax positions not impacting the effective tax rate	438		—		438		423
Balance of unrecognized tax benefits	$	439	$	19	$	458	$	433

The tax positions impacting the effective tax rate primarily relate to federal income tax benefits from ITCs and Southern Company's estimate of the uncertainty related to the amount of those benefits. The impact on the effective tax rate is determined based on the amount of ITCs, which is uncertain. If these tax positions are not able to be recognized due to a federal audit adjustment equal to the estimated amount, the amount of tax credit carryforwards discussed above would be reduced by approximately $94 million.

Accrued interest for all tax positions other than Section 174 R&E deductions disclosed below was immaterial for all periods presented.

All of the registrants classify interest on tax uncertainties as interest expense. None of the registrants accrued any penalties on uncertain tax positions.

It is reasonably possible that the amount of the unrecognized tax benefits could change within 12 months. The settlement of federal and state audits could impact the balances significantly. At this time, an estimate of the range of reasonably possible outcomes cannot be determined.

The IRS has finalized its audits of Southern Company's consolidated federal income tax returns through 2012. Southern Company has filed its 2013, 2014, and 2015 federal income tax returns and has received partial acceptance letters from the IRS; however, the IRS has not finalized its audits. Southern Company is a participant in the Compliance Assurance Process of the IRS. The audits for the Southern Company's state income tax returns have either been concluded, or the statute of limitations has expired, for years prior to 2011.

Section 174 Research and Experimental Deduction

Southern Company has reflected deductions for R&E expenditures related to the Kemper IGCC in its federal income tax calculations since 2013 and has filed amended federal income tax returns for 2008 through 2013 to also include such deductions.

The Kemper IGCC is based on first-of-a-kind technology, and Southern Company and Mississippi Power believe that a significant portion of the plant costs qualify as deductible R&E expenditures under Internal Revenue Code Section 174. Subsequent to September 30, 2016, Southern Company and Mississippi Power responded to a notice of proposed assessment from the IRS, which is continuing to review the underlying support for the deduction. Due to the uncertainty related to this tax position, Southern Company and Mississippi Power had related unrecognized tax benefits associated with these R&E deductions of approximately $438 million and associated interest of $24 million as of September 30, 2016. It is reasonably possible that this matter will be resolved in the next 12 months; however, the ultimate outcome of this matter cannot be determined at this time.