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Income Taxes
12 Months Ended
Dec. 31, 2015
Income Taxes
INCOME TAXES (Entergy Corporation, Entergy Arkansas, Entergy Louisiana, Entergy Mississippi, Entergy New Orleans, Entergy Texas, and System Energy)

Income taxes for 2015, 2014, and 2013 for Entergy Corporation and Subsidiaries consist of the following:
 
2015
 
2014
 
2013
 
(In Thousands)
Current:
 
 
 
 
 
Federal

$77,166

 

$90,061

 

$88,291

Foreign
97

 
90

 
101

State
157,829

 
(12,637
)
 
20,584

Total
235,092

 
77,514

 
108,976

Deferred and non-current - net
(864,799
)
 
528,326

 
126,935

Investment tax credit adjustments - net
(13,220
)
 
(16,243
)
 
(9,930
)
Income taxes

($642,927
)
 

$589,597

 

$225,981



Income taxes for 2015, 2014, and 2013 for Entergy’s Registrant Subsidiaries consist of the following:
2015
 
Entergy
Arkansas
 
Entergy
Louisiana
 
Entergy
Mississippi
 
Entergy
New Orleans
 
Entergy
Texas
 
System
Energy
 
 
(In Thousands)
Current:
 
 
 
 
 
 
 
 
 
 
 
 
Federal
 

$66,966

 

$101,382

 

$25,628

 

($9,346
)
 

$53,313

 

($63,302
)
State
 
6,265

 
35,406

 
6,832

 
1,784

 
2,450

 
26,755

Total
 
73,231

 
136,788

 
32,460

 
(7,562
)
 
55,763

 
(36,547
)
Deferred and non-current - net
 
(31,463
)
 
47,220

 
31,149

 
32,890

 
(17,599
)
 
93,491

Investment tax credit adjustments - net
 
(1,227
)
 
(5,337
)
 
(1,737
)
 
(138
)
 
(914
)
 
(3,867
)
Income taxes
 

$40,541

 

$178,671

 

$61,872

 

$25,190

 

$37,250

 

$53,077


2014
 
Entergy
Arkansas
 
Entergy
Louisiana
 
Entergy
Mississippi
 
Entergy
New Orleans
 
Entergy
Texas
 
System
Energy
 
 
(In Thousands)
Current:
 
 
 
 
 
 
 
 
 
 
 
 
Federal
 

($34,258
)
 

($44,909
)
 

$8,103

 

($1,428
)
 

$48,610

 

$19,908

State
 
(678
)
 
(1,191
)
 
7,474

 
510

 
4,877

 
15,379

Total
 
(34,936
)
 
(46,100
)
 
15,577

 
(918
)
 
53,487

 
35,287

Deferred and non-current - net
 
119,841

 
236,794

 
42,305

 
14,592

 
(2,418
)
 
53,501

Investment tax credit adjustments - net
 
(1,276
)
 
(5,642
)
 
(2,172
)
 
(224
)
 
(1,425
)
 
(5,478
)
Income taxes
 

$83,629

 

$185,052

 

$55,710

 

$13,450

 

$49,644

 

$83,310


2013
 
Entergy
Arkansas
 
Entergy
Louisiana
 
Entergy
Mississippi
 
Entergy
New Orleans
 
Entergy
Texas
 
System
Energy
 
 
(In Thousands)
Current:
 
 
 
 
 
 
 
 
 
 
 
 
Federal
 

($13,574
)
 

($18,797
)
 

$2,498

 

$14,823

 

$37,199

 

($6,199
)
State
 
6,122

 
(15,631
)
 
4,849

 
(1,267
)
 
(843
)
 
15,845

Total
 
(7,452
)
 
(34,428
)
 
7,347

 
13,556

 
36,356

 
9,646

Deferred and non-current - net
 
101,253

 
179,036

 
41,150

 
(11,033
)
 
(4,639
)
 
60,614

Investment tax credit adjustments - net
 
(2,014
)
 
(5,912
)
 
1,260

 
(246
)
 
(1,609
)
 
(1,407
)
Income taxes
 

$91,787

 

$138,696

 

$49,757

 

$2,277

 

$30,108

 

$68,853



Total income taxes for Entergy Corporation and Subsidiaries differ from the amounts computed by applying the statutory income tax rate to income before income taxes.  The reasons for the differences for the years 2015, 2014, and 2013 are:
 
2015
 
2014
 
2013
 
(In Thousands)
Net income (loss) attributable to Entergy Corporation

($176,562
)
 

$940,721

 

$711,902

Preferred dividend requirements of subsidiaries
19,828

 
19,536

 
18,670

Consolidated net income (loss)
(156,734
)
 
960,257

 
730,572

Income taxes
(642,927
)
 
589,597

 
225,981

Income (loss) before income taxes

($799,661
)
 

$1,549,854

 

$956,553

Computed at statutory rate (35%)

($279,881
)
 

$542,449

 

$334,794

Increases (reductions) in tax resulting from:
 

 
 

 
 

State income taxes net of federal income tax effect
29,944

 
44,708

 
13,599

Regulatory differences - utility plant items
32,089

 
39,321

 
32,324

Equity component of AFUDC
(18,191
)
 
(21,108
)
 
(22,356
)
Amortization of investment tax credits
(11,136
)
 
(12,211
)
 
(13,535
)
Flow-through / permanent differences
(7,872
)
 
(18,003
)
 
(301
)
Net-of-tax regulatory liability

 

 
(2,899
)
New York tax law change (a)

 
(21,500
)
 

Louisiana business combination
(333,655
)
 

 

Termination of business reorganization

 

 
(27,192
)
Provision for uncertain tax positions (b)
(56,683
)
 
32,573

 
(59,249
)
Valuation allowance

 

 
(31,573
)
Other - net
2,458

 
3,368

 
2,369

Total income taxes as reported

($642,927
)
 

$589,597

 

$225,981

Effective Income Tax Rate
80.4
%
 
38.0
%
 
23.6
%


(a)
In March 2014, New York enacted legislation that substantially modifies various aspects of New York tax law. The most significant effect of the legislation for Entergy is the adoption of full water’s-edge unitary combined reporting, meaning that all of Entergy’s domestic entities will be included in New York’s combined filing group. The effect of the tax law change resulted in a deferred state income tax reduction of approximately $21.5 million as shown in the table above.
(b)
See “Income Tax Audits - 2008-2009 IRS Audit” below for discussion of the most significant items for 2015 and 2013.

Total income taxes for the Registrant Subsidiaries differ from the amounts computed by applying the statutory income tax rate to income before taxes.  The reasons for the differences for the years 2015, 2014, and 2013 are:
2015
 
Entergy
Arkansas
 
Entergy
Louisiana
 
Entergy
Mississippi
 
Entergy
New Orleans
 
Entergy
Texas
 
System
Energy
 
 
(In Thousands)
Net income
 

$74,272

 

$446,639

 

$92,708

 

$44,925

 

$69,625

 

$111,318

Income taxes
 
40,541

 
178,671

 
61,872

 
25,190

 
37,250

 
53,077

Pretax income
 

$114,813

 

$625,310

 

$154,580

 

$70,115

 

$106,875

 

$164,395

Computed at statutory rate (35%)
 

$40,185

 

$218,859

 

$54,103

 

$24,540

 

$37,406

 

$57,538

Increases (reductions) in tax resulting from:
 
 
 
 

 
 

 
 

 
 

 
 

State income taxes net of federal income tax effect
 
6,643

 
23,650

 
5,219

 
2,887

 
1,621

 
6,403

Regulatory differences - utility plant items
 
7,299

 
3,013

 
2,383

 
2,201

 
3,703

 
12,167

Equity component of AFUDC
 
(4,979
)
 
(5,420
)
 
(1,083
)
 
(451
)
 
(1,987
)
 
(2,973
)
Amortization of investment tax credits
 
(1,201
)
 
(5,252
)
 
(160
)
 
(111
)
 
(900
)
 
(3,476
)
Flow-through / permanent differences
 
(4,062
)
 
2,460

 
431

 
(4,539
)
 
530

 
618

Non-taxable dividend income
 

 
(44,658
)
 

 

 

 

Provision for uncertain tax positions (a)
 
(3,978
)
 
(15,377
)
 
756

 
525

 
(3,365
)
 
(17,313
)
Other - net
 
634

 
1,396

 
223

 
138

 
242

 
113

Total income taxes
 

$40,541

 

$178,671

 

$61,872

 

$25,190

 

$37,250

 

$53,077

Effective Income Tax Rate
 
35.3
%
 
28.6
%
 
40.0
%
 
35.9
%
 
34.9
%
 
32.3
%


(a)
See “Income Tax Audits - 2008-2009 IRS Audit” below for discussion of the most significant items for Entergy Louisiana and System Energy.

2014
 
Entergy
Arkansas
 
Entergy
Louisiana
 
Entergy
Mississippi
 
Entergy
New Orleans
 
Entergy
Texas
 
System
Energy
 
 
(In Thousands)
Net income
 

$121,392

 

$446,022

 

$74,821

 

$31,030

 

$74,804

 

$96,334

Income taxes
 
83,629

 
185,052

 
55,710

 
13,450

 
49,644

 
83,310

Pretax income
 

$205,021

 

$631,074

 

$130,531

 

$44,480

 

$124,448

 

$179,644

Computed at statutory rate (35%)
 

$71,757

 

$220,876

 

$45,686

 

$15,568

 

$43,557

 

$62,875

Increases (reductions) in tax resulting from:
 
 

 
 

 
 

 
 

 
 

 
 

State income taxes net of federal income tax effect
 
9,591

 
11,666

 
5,180

 
1,562

 
3,221

 
6,877

Regulatory differences - utility plant items
 
8,653

 
7,487

 
4,448

 
777

 
4,165

 
13,791

Equity component of AFUDC
 
(2,533
)
 
(14,612
)
 
(833
)
 
(320
)
 
(1,035
)
 
(1,774
)
Amortization of investment tax credits
 
(1,251
)
 
(5,594
)
 
(260
)
 
(218
)
 
(1,412
)
 
(3,476
)
Flow-through / permanent differences
 
(5,082
)
 
(225
)
 
555

 
(4,458
)
 
393

 
(327
)
Non-taxable dividend income
 

 
(41,255
)
 

 

 

 

Provision for uncertain tax positions
 
1,881

 
5,336

 
718

 
405

 
522

 
5,235

Other - net
 
613

 
1,373

 
216

 
134

 
233

 
109

Total income taxes
 

$83,629

 

$185,052

 

$55,710

 

$13,450

 

$49,644

 

$83,310

Effective Income Tax Rate
 
40.8
%
 
29.3
%
 
42.7
%
 
30.2
%
 
39.9
%
 
46.4
%


2013
 
Entergy
Arkansas
 
Entergy
Louisiana
 
Entergy
Mississippi
 
Entergy
New Orleans
 
Entergy
Texas
 
System
Energy
 
 
(In Thousands)
Net income
 

$161,948

 

$414,126

 

$82,159

 

$12,608

 

$57,881

 

$113,664

Income taxes
 
91,787

 
138,696

 
49,757

 
2,277

 
30,108

 
68,853

Pretax income
 

$253,735

 

$552,822

 

$131,916

 

$14,885

 

$87,989

 

$182,517

Computed at statutory rate (35%)
 

$88,807

 

$193,488

 

$46,171

 

$5,210

 

$30,796

 

$63,881

Increases (reductions) in tax resulting from:
 
 

 
 

 
 

 
 

 
 

 
 

State income taxes net of federal income tax effect
 
10,954

 
19,084

 
4,564

 
1,116

 
(897
)
 
5,900

Regulatory differences - utility plant items
 
7,938

 
7,005

 
2,603

 
453

 
3,256

 
11,070

Equity component of AFUDC
 
(3,820
)
 
(13,100
)
 
(764
)
 
(322
)
 
(1,626
)
 
(2,724
)
Amortization of investment tax credits
 
(1,989
)
 
(5,864
)
 
(260
)
 
(216
)
 
(1,596
)
 
(3,476
)
Flow-through / permanent differences
 
2,540

 
3,646

 
1,702

 
(4,402
)
 
2,467

 
(491
)
Net-of-tax regulatory liability
 

 
(2,899
)
 

 

 

 

Termination of business organization
 
(6,753
)
 
(7,453
)
 
(4,177
)
 
(501
)
 
(3,542
)
 
(13
)
Non-taxable dividend income
 

 
(36,953
)
 

 

 

 

Provision for uncertain tax positions (a)
 
(6,527
)
 
(18,645
)
 
(326
)
 
795

 
1,027

 
(5,353
)
Other - net
 
637

 
387

 
244

 
144

 
223

 
59

Total income taxes
 

$91,787

 

$138,696

 

$49,757

 

$2,277

 

$30,108

 

$68,853

Effective Income Tax Rate
 
36.2
%
 
25.1
%
 
37.7
%
 
15.3
%
 
34.2
%
 
37.7
%


(a)
See “Income Tax Audits - 2008-2009 IRS Audit” below for discussion of the most significant items for Entergy Louisiana and System Energy.

Significant components of accumulated deferred income taxes and taxes accrued for Entergy Corporation and Subsidiaries as of December 31, 2015 and 2014 are as follows:
 
 
2015
 
2014
 
(In Thousands)
Deferred tax liabilities:
 
 
 
Plant basis differences - net

($6,804,225
)
 

($8,128,096
)
Regulatory assets
(646,392
)
 
(922,161
)
Nuclear decommissioning trusts
(1,254,463
)
 
(1,248,737
)
Pension, net funding
(365,111
)
 
(324,881
)
Combined unitary state taxes
(45,078
)
 
(162,340
)
Power purchase agreements

 
(110,889
)
Other
(315,844
)
 
(500,424
)
Total
(9,431,113
)
 
(11,397,528
)
Deferred tax assets:
 

 
 

Nuclear decommissioning liabilities
828,983

 
874,493

Regulatory liabilities
284,432

 
458,230

Pension and other post-employment benefits
525,524

 
586,455

Sale and leaseback
139,720

 
153,308

Compensation
69,432

 
74,692

Accumulated deferred investment tax credit
95,248

 
100,442

Provision for allowances and contingencies
188,282

 
160,551

Power purchase agreements
38,401

 

Net operating loss carryforwards
360,188

 
457,758

Capital losses and miscellaneous tax credits
11,075

 
12,146

Valuation allowance
(91,532
)
 
(27,387
)
Other
68,204

 
58,334

Total
2,517,957

 
2,909,022

Non-current accrued taxes (including unrecognized tax benefits)
(1,338,806
)
 
(606,560
)
Accumulated deferred income taxes and taxes accrued

($8,251,962
)
 

($9,095,066
)


Entergy’s estimated tax attributes carryovers and their expiration dates as of December 31, 2015 are as follows:
Carryover Description
 
Carryover Amount
 
Year(s) of expiration
 
 
 
 
 
Federal net operating losses
 
$3.6 billion
 
2023-2035
State net operating losses
 
$5.2 billion
 
2016-2035
Miscellaneous federal and state credits
 
$77.9 million
 
2016-2035


As a result of the accounting for uncertain tax positions, the amount of the deferred tax assets reflected in the financial statements is less than the amount of the tax effect of the federal and state net operating loss carryovers, tax credit carryovers, and other tax attributes reflected on income tax returns. Because it is more likely than not that the benefit from certain state net operating loss carryovers will not be utilized, valuation allowances of $46 million as of December 31, 2015 and $21 million as of December 31, 2014 have been provided on the deferred tax assets relating to these state net operating loss carryovers. Additionally, valuation allowances totaling $45.5 million as of December 31, 2015 have been provided on deferred tax assets related to state jurisdictions in which Entergy does not currently expect to be able to utilize separate company tax return losses, preventing realization of such deferred tax assets.
Significant components of accumulated deferred income taxes and taxes accrued for the Registrant Subsidiaries as of December 31, 2015 and 2014 are as follows:
2015
Entergy
Arkansas
 
Entergy
Louisiana
 
Entergy
Mississippi
 
Entergy
New Orleans
 
Entergy
Texas
 
System
Energy
 
(In Thousands)
Deferred tax liabilities:
 
 
 
 
 
 
 
 
 
 
 
Plant basis differences - net

($1,710,444
)
 

($2,041,968
)
 

($781,427
)
 

($167,294
)
 

($778,270
)
 

($611,745
)
Regulatory assets
(108,422
)
 
(254,316
)
 
(24,918
)
 
(39,451
)
 
(172,117
)
 
(46,990
)
Nuclear decommissioning trusts
(121,326
)
 
(99,980
)
 

 

 

 
(68,370
)
Pension, net funding
(107,073
)
 
(109,709
)
 
(30,901
)
 
(14,459
)
 
(28,001
)
 
(25,791
)
Deferred fuel
(7,647
)
 
(2,513
)
 
(684
)
 
(175
)
 
2,050

 
(18
)
Other
(38,683
)
 
(86,275
)
 
(5,625
)
 
(12,253
)
 
(10,109
)
 
(22,478
)
Total
(2,093,595
)
 
(2,594,761
)
 
(843,555
)
 
(233,632
)
 
(986,447
)
 
(775,392
)
Deferred tax assets:
 

 
 

 
 

 
 

 
 

 
 

Regulatory liabilities
18,369

 
215,154

 
7,787

 
20,888

 
7,307

 
14,927

Nuclear decommissioning liabilities
109,962

 
49,333

 

 

 

 
39,420

Pension and other post-employment benefits
(20,420
)
 
149,680

 
(6,628
)
 
(8,939
)
 
(16,703
)
 
(1,037
)
Sale and leaseback

 
37,236

 

 

 

 
102,484

Accumulated deferred investment tax credit
14,320

 
56,635

 
1,777

 
290

 
4,842

 
17,385

Provision for allowances and contingencies
1,024

 
123,007

 
18,735

 
33,843

 
7,266

 
134

Power purchase agreements
(1,279
)
 
13,840

 
1,901

 
13

 
575

 

Unbilled/deferred revenues
9,815

 
(32,365
)
 
7,154

 
2,126

 
10,851

 

Compensation
1,842

 
4,182

 
601

 
880

 
4,496

 

Net operating loss carryforwards

 
90,241

 

 

 

 

Other
128

 
21,982

 
1,995

 
316

 
1,672

 

Total
133,761

 
728,925

 
33,322

 
49,417

 
20,306

 
173,313

Non-current accrued taxes (including unrecognized tax benefits)
(22,978
)
 
(641,120
)
 
(402
)
 
(29,846
)
 
(40,693
)
 
(416,996
)
Accumulated deferred income taxes and taxes accrued

($1,982,812
)
 

($2,506,956
)
 

($810,635
)
 

($214,061
)
 

($1,006,834
)
 

($1,019,075
)
2014
 
Entergy
Arkansas
 
Entergy
Louisiana
 
Entergy
Mississippi
 
Entergy
New Orleans
 
Entergy
Texas
 
System
Energy
 
 
(In Thousands)
Deferred tax liabilities:
 
 
 
 
 
 
 
 
 
 
 
 
Plant basis differences - net
 

($1,657,503
)
 

($2,748,852
)
 

($753,576
)
 

($186,153
)
 

($771,135
)
 

($668,779
)
Regulatory assets
 
(198,662
)
 
(380,719
)
 
(30,114
)
 

 
(202,402
)
 
(110,087
)
Nuclear decommissioning trusts
 
(130,524
)
 
(106,162
)
 

 

 

 
(74,063
)
Pension, net funding
 
(93,355
)
 
(99,593
)
 
(27,861
)
 
(13,285
)
 
(25,616
)
 
(23,440
)
Deferred fuel
 
(82,050
)
 
(3,534
)
 
(5,303
)
 
(407
)
 
2,045

 
(120
)
Power purchase agreements
 
(17,073
)
 
(67,083
)
 
2,129

 
13

 
847

 

Other
 
(33,827
)
 
(84,282
)
 
(11,423
)
 
(11,500
)
 
(22,546
)
 
(19,802
)
Total
 
(2,212,994
)
 
(3,490,225
)
 
(826,148
)
 
(211,332
)
 
(1,018,807
)
 
(896,291
)
Deferred tax assets:
 
 

 
 

 
 

 
 

 
 

 
 

Regulatory liabilities
 
145,466

 
181,601

 
7,214

 
29,580

 
4,079

 
90,290

Nuclear decommissioning liabilities
 
(43,134
)
 
146,138

 

 

 

 
(62,571
)
Pension and other post-employment benefits
 
(17,534
)
 
158,661

 
(7,288
)
 
(7,504
)
 
(15,053
)
 
(1,413
)
Sale and leaseback
 

 
45,136

 

 

 

 
108,172

Accumulated deferred investment tax credit
 
14,791

 
58,863

 
2,436

 
332

 
5,158

 
18,862

Provision for allowances and contingencies
 
(7,149
)
 
125,805

 
19,590

 
10,986

 
8,017

 
133

Unbilled/deferred revenues
 
12,322

 
(25,016
)
 
12,956

 
3,395

 
11,573

 

Compensation
 
2,085

 
158

 
(846
)
 
475

 
4,155

 

Net operating loss carryforwards
 
105,063

 
241,803

 

 

 

 

Capital losses and miscellaneous tax credits
 

 

 
3,504

 

 

 

Other
 
258

 
15,508

 
5,887

 
2,891

 
3,850

 
2,000

Total
 
212,168

 
948,657

 
43,453

 
40,155

 
21,779

 
155,473

Non-current accrued taxes (including unrecognized tax benefits)
 
9,367

 
(412,508
)
 
(12,481
)
 
(19,502
)
 
(48,921
)
 
(81,528
)
Accumulated deferred income taxes and taxes accrued
 

($1,991,459
)
 

($2,954,076
)
 

($795,176
)
 

($190,679
)
 

($1,045,949
)
 

($822,346
)


The Registrant Subsidiaries’ estimated tax attributes carryovers and their expiration dates as of December 31, 2015 are as follows:
 
 
 
Entergy
Arkansas
 
 
Entergy
Louisiana
 
 
Entergy
Mississippi
 
Entergy
New Orleans
 
 
Entergy
Texas
 
 
System
Energy
 
 
 
 
 
 
 
 
 
 
 
 
 
Federal net operating losses
 
$7 million
 
$2.4 billion
 
 
 
 
$242 million
Year(s) of expiration
 
2030-2035
 
2035
 
N/A
 
N/A
 
N/A
 
2030-2035
 
 
 
 
 
 
 
 
 
 
 
 
 
State net operating losses
 
 
$2.5 billion
 
 
$6 million
 
 
$833 million
Year(s) of expiration
 
N/A
 
2035
 
N/A
 
2032
 
N/A
 
2035
 
 
 
 
 
 
 
 
 
 
 
 
 
Misc. federal credits
 
$1 million
 
 
$1 million
 
 
 
$1 million
Year(s) of expiration
 
2029-2033
 
N/A
 
2029-2034
 
N/A
 
N/A
 
2029-2033
 
 
 
 
 
 
 
 
 
 
 
 
 
State credits
 
 
 
 
 
$3.3 million
 
$6 million
Year(s) of expiration
 
N/A
 
N/A
 
N/A
 
N/A
 
2026
 
2017-2020


As a result of the accounting for uncertain tax positions, the amount of the deferred tax assets reflected in the financial statements is less than the amount of the tax effect of the federal and state net operating loss carryovers and tax credit carryovers.

Unrecognized tax benefits

Accounting standards establish a “more-likely-than-not” recognition threshold that must be met before a tax benefit can be recognized in the financial statements.  If a tax deduction is taken on a tax return, but does not meet the more-likely-than-not recognition threshold, an increase in income tax liability, above what is payable on the tax return, is required to be recorded.  A reconciliation of Entergy’s beginning and ending amount of unrecognized tax benefits is as follows:
 
2015
 
2014
 
2013
 
(In Thousands)
Gross balance at January 1

$4,736,785

 

$4,593,224

 

$4,170,403

Additions based on tax positions related to the current year
1,850,705

 
348,543

 
162,338

Additions for tax positions of prior years
59,815

 
11,637

 
410,108

Reductions for tax positions of prior years (a)
(3,966,535
)
 
(213,401
)
 
(103,360
)
Settlements
(68,227
)
 

 
(43,620
)
Lapse of statute of limitations
(958
)
 
(3,218
)
 
(2,645
)
Gross balance at December 31
2,611,585

 
4,736,785

 
4,593,224

Offsets to gross unrecognized tax benefits:
 

 
 

 
 

Credit and loss carryovers
(1,264,483
)
 
(4,295,643
)
 
(4,400,498
)
Unrecognized tax benefits net of unused tax attributes and payments (b)

$1,347,102

 

$441,142

 

$192,726



(a)
The primary reduction is related to the nuclear decommissioning costs treatment discussed in “Income Tax Audits - 2008-2009 IRS Audit” below.
(b)
Potential tax liability above what is payable on tax returns

The balances of unrecognized tax benefits include $955 million, $516 million, and $176 million as of December 31, 2015, 2014, and 2013, respectively, which, if recognized, would lower the effective income tax rates.  Because of the effect of deferred tax accounting, the remaining balances of unrecognized tax benefits of $1.657 billion, $4.221 billion, and $4.417 billion as of December 31, 2015, 2014, and 2013, respectively, if disallowed, would not affect the annual effective income tax rate but would accelerate the payment of cash to the taxing authority to an earlier period.

Entergy accrues interest expense, if any, related to unrecognized tax benefits in income tax expense.  Entergy’s December 31, 2015, 2014, and 2013 accrued balance for the possible payment of interest is approximately $27 million, $127 million, and $96.4 million, respectively.

A reconciliation of the Registrant Subsidiaries’ beginning and ending amount of unrecognized tax benefits for 2015, 2014, and 2013 is as follows:
2015
 
Entergy
Arkansas
 
Entergy
Louisiana
 
Entergy
Mississippi
 
Entergy
New Orleans
 
Entergy
Texas
 
System
Energy
 
 
(In Thousands)
Gross balance at January 1, 2015
 

$362,912

 

$1,205,929

 

$20,144

 

$53,763

 

$17,264

 

$258,242

Additions based on tax positions related to the current year (a)
 
2,196

 
1,367,058

 
566

 
472

 
657

 
472,304

Additions for tax positions of prior years
 
1,057

 
7,992

 
8,140

 
48

 
2,914

 
913

Reductions for tax positions of prior years
 
(340,720
)
 
(859,430
)
 

 
(386
)
 
(3,981
)
 
(253,141
)
Settlements
 

 
(30,888
)
 
(9,368
)
 

 
(3,392
)
 

Gross balance at December 31, 2015
 
25,445

 
1,690,661

 
19,482

 
53,897

 
13,462

 
478,318

Offsets to gross unrecognized tax benefits:
 
 

 
 

 
 

 
 

 
 

 
 

Loss carryovers
 
(3,613
)
 
(893,764
)
 
(1,016
)
 
(506
)
 
(276
)
 
(133,611
)
Unrecognized tax benefits net of unused tax attributes and payments
 

$21,832

 

$796,897

 

$18,466

 

$53,391

 

$13,186

 

$344,707



(a)
The primary addition for Entergy Louisiana and System Energy is related to the nuclear decommissioning costs treatment discussed in “Other Tax Matters” below.

2014
 
Entergy
Arkansas
 
Entergy
Louisiana
 
Entergy
Mississippi
 
Entergy
New Orleans
 
Entergy
Texas
 
System
Energy
 
 
(In Thousands)
Gross balance at January 1, 2014
 

$347,713

 

$1,076,680

 

$16,186

 

$51,679

 

$13,017

 

$265,185

Additions based on tax positions related to the current year
 
14,511

 
151,249

 
3,928

 
2,235

 
4,225

 
2,744

Additions for tax positions of prior years
 
1,767

 
6,924

 
319

 
37

 
303

 
566

Reductions for tax positions of prior years
 
(1,079
)
 
(28,924
)
 
(289
)
 
(188
)
 
(267
)
 
(10,253
)
Settlements
 

 

 

 

 
(14
)
 

Gross balance at December 31, 2014
 
362,912

 
1,205,929

 
20,144

 
53,763

 
17,264

 
258,242

Offsets to gross unrecognized tax benefits:
 
 

 
 

 
 

 
 

 
 

 
 

Loss carryovers
 
(361,043
)
 
(739,988
)
 
(6,992
)
 
(20,735
)
 
(241
)
 
(163,124
)
Unrecognized tax benefits net of unused tax attributes and payments
 

$1,869

 

$465,941

 

$13,152

 

$33,028

 

$17,023

 

$95,118


2013
 
Entergy
Arkansas
 
Entergy
Louisiana
 
Entergy
Mississippi
 
Entergy
New Orleans
 
Entergy
Texas
 
System
Energy
 
 
(In Thousands)
Gross balance at January 1, 2013
 

$344,669

 

$1,002,394

 

$16,841

 

$52,018

 

$13,954

 

$260,346

Additions based on tax positions related to the current year
 
6,427

 
17,887

 
957

 
583

 
2,170

 
4,170

Additions for tax positions of prior years
 
1,228

 
125,214

 
401

 
3,506

 
587

 
8,391

Reductions for tax positions of prior years
 
(3,943
)
 
(53,473
)
 
(1,941
)
 
(962
)
 
(4,186
)
 
(967
)
Settlements
 
(668
)
 
(15,342
)
 
(72
)
 
(3,466
)
 
492

 
(6,755
)
Gross balance at December 31, 2013
 
347,713

 
1,076,680

 
16,186

 
51,679

 
13,017

 
265,185

Offsets to gross unrecognized tax benefits:
 
 

 
 

 
 

 
 

 
 

 
 

Loss carryovers
 
(345,674
)
 
(747,756
)
 
(16,186
)
 
(22,078
)
 
(266
)
 
(225,286
)
Unrecognized tax benefits net of unused tax attributes and payments
 

$2,039

 

$328,924

 

$—

 

$29,601

 

$12,751

 

$39,899



The Registrant Subsidiaries’ balances of unrecognized tax benefits included amounts which, if recognized, would have reduced income tax expense as follows:
 
December 31,
 
2015
 
2014
 
2013
 
(In Millions)
Entergy Arkansas

$4.5

 

$2.6

 

$0.6

Entergy Louisiana

$692.7

 

$267.3

 

$131.9

Entergy Mississippi

$8.1

 

$3.9

 

$3.9

Entergy New Orleans

$50.7

 

$50.7

 

$—

Entergy Texas

$5.2

 

$10.5

 

$10.1

System Energy

$0.7

 

$3.7

 

$3.3



The Registrant Subsidiaries accrue interest and penalties related to unrecognized tax benefits in income tax expense.  Penalties have not been accrued.  Accrued balances for the possible payment of interest are as follows:
 
December 31,
 
2015
 
2014
 
2013
 
(In Millions)
Entergy Arkansas

$1.3

 

$17.0

 

$15.2

Entergy Louisiana

$9.3

 

$22.2

 

$18.0

Entergy Mississippi

$0.4

 

$2.8

 

$2.1

Entergy New Orleans

$1.8

 

$1.3

 

$0.9

Entergy Texas

$1.2

 

$1.0

 

$0.8

System Energy

$0.7

 

$23.8

 

$19.0



Income Tax Audits

Entergy and its subsidiaries file U.S. federal and various state and foreign income tax returns.  IRS examinations are complete for years before 2010. All state taxing authorities’ examinations are completed for years before 2009.

2006-2007 IRS Audit

In the first quarter 2015, the IRS finalized tax and interest computations from the 2006-2007 audit that resulted in a reversal of Entergy’s provision for uncertain tax positions related to accrued interest of approximately $20 million, including decreases of approximately $4 million for Entergy Arkansas, $11 million for Entergy Louisiana, and $1 million for System Energy.

2008-2009 IRS Audit

In the fourth quarter 2009, Entergy filed Applications for Change in Accounting Method (the “2009 CAM”) for tax purposes with the IRS for certain costs under Section 263A of the Internal Revenue Code.  In the Applications, Entergy proposed to treat the nuclear decommissioning liability associated with the operation of its nuclear power plants as a production cost properly includable in cost of goods sold.  The effect of the 2009 CAM was a $5.7 billion reduction in 2009 taxable income.  The 2009 CAM was adjusted to $9.3 billion in 2012.

In the fourth quarter 2012 the IRS disallowed the reduction to 2009 taxable income related to the 2009 CAM.  In the third quarter 2013, the Internal Revenue Service issued its RAR for the tax years 2008-2009. As a result of the issuance of this RAR, Entergy and the IRS resolved all of the 2008-2009 issues described above except for the 2009 CAM. Entergy disagreed with the IRS’s disallowance of the 2009 CAM and filed a protest with the IRS Appeals Division in October 2013.

In August 2015, Entergy and the IRS agreed on the treatment of the 2009 position regarding nuclear decommissioning liabilities from the 2008-2009 audit. The agreement provides that Entergy is entitled to deduct approximately $118 million of the $9.3 billion claimed in 2009. The agreement effectively settled all matters pertaining to the 2009 tax year and increased Entergy’s 2009 federal income tax liability by $2.4 million.

2010-2011 IRS Audit

The IRS examination of the 2010 and 2011 years is ongoing and the audit field work is expected to be completed by the end of the first quarter of 2016. The IRS has not issued any significant notices of proposed adjustments other than for the decommissioning liability position discussed above. The Revenue Agent’s Report is expected to be received shortly after the completion of field work.

Other Tax Matters

Entergy regularly negotiates with the IRS to achieve settlements.  The resolution of audit issues could result in significant changes to the amounts of unrecognized tax benefits in the next twelve months.

In September 2013 the U.S. Treasury Department and the IRS issued final regulations that provide guidance on the deductibility and capitalization of costs incurred associated with tangible property. Entergy and the Registrant Subsidiaries filed with the IRS an automatic application for change in accounting method which is in compliance with the final regulations and the safe harbor provisions of the relevant IRS Revenue Procedures. Entergy estimates that the effect of this accounting method change will result in a net increase to Entergy’s taxable income of approximately $585 million, which will be recognized generally over a four year period beginning with the tax year ended 2014. The adoption of the final regulations and safe harbor method results in approximate changes in the Registrant Subsidiaries taxable income as follows: an increase of $177 million for Entergy Arkansas, an increase of $78 million for Entergy Louisiana, an increase of $26 million for Entergy Mississippi, an increase of $183 million for Entergy Texas, a decrease of $2 million for Entergy New Orleans, and an increase of $22 million for System Energy.

In October 2015 two of Entergy’s Louisiana utilities, Entergy Gulf States Louisiana and Entergy Louisiana, combined their businesses into a legal entity which is identified as Entergy Louisiana herein. Entergy Louisiana maintained a carryover tax basis in the assets received. Additionally, the tax consequences provided for an increase in tax basis as well. To the extent that this increase in tax basis will provide additional tax depreciation, Entergy recorded a deferred tax asset and current tax expense resulting in a net increase in tax basis of approximately $334 million and Entergy Louisiana obtained a corresponding deferred tax asset. Consistent with the terms of an agreement with the LPSC, electric customers of Entergy Louisiana will realize customer credits associated with the business combination. Accordingly, in October 2015, Entergy recorded a regulatory liability of $107 million ($66 million net-of-tax) which partially offsets the effect of the aforementioned deferred tax asset. The deferred tax asset and the regulatory liability, net-of-tax, increased Entergy Louisiana’s member’s equity by $268 million. See Note 2 to the financial statements for further discussion of the business combination.

In the fourth quarter 2015, System Energy and Entergy Louisiana adopted a new method of accounting for income tax purposes in which the companies’ nuclear decommissioning costs will be treated as production costs of electricity includable in cost of goods sold. The new method results in a reduction of taxable income of $1.2 billion for System Energy and $2.2 billion for Entergy Louisiana.

The Protecting Americans from Tax Hikes Act of 2015 was enacted in December 2015. The most significant provisions affecting Entergy and the Registrant Subsidiaries were a five-year extension of bonus depreciation and permanent extension of the research and experimentation tax credit. The effect of the bonus depreciation extension on 2015 increased Entergy’s tax net operating loss.
Entergy Arkansas [Member]  
Income Taxes
INCOME TAXES (Entergy Corporation, Entergy Arkansas, Entergy Louisiana, Entergy Mississippi, Entergy New Orleans, Entergy Texas, and System Energy)

Income taxes for 2015, 2014, and 2013 for Entergy Corporation and Subsidiaries consist of the following:
 
2015
 
2014
 
2013
 
(In Thousands)
Current:
 
 
 
 
 
Federal

$77,166

 

$90,061

 

$88,291

Foreign
97

 
90

 
101

State
157,829

 
(12,637
)
 
20,584

Total
235,092

 
77,514

 
108,976

Deferred and non-current - net
(864,799
)
 
528,326

 
126,935

Investment tax credit adjustments - net
(13,220
)
 
(16,243
)
 
(9,930
)
Income taxes

($642,927
)
 

$589,597

 

$225,981



Income taxes for 2015, 2014, and 2013 for Entergy’s Registrant Subsidiaries consist of the following:
2015
 
Entergy
Arkansas
 
Entergy
Louisiana
 
Entergy
Mississippi
 
Entergy
New Orleans
 
Entergy
Texas
 
System
Energy
 
 
(In Thousands)
Current:
 
 
 
 
 
 
 
 
 
 
 
 
Federal
 

$66,966

 

$101,382

 

$25,628

 

($9,346
)
 

$53,313

 

($63,302
)
State
 
6,265

 
35,406

 
6,832

 
1,784

 
2,450

 
26,755

Total
 
73,231

 
136,788

 
32,460

 
(7,562
)
 
55,763

 
(36,547
)
Deferred and non-current - net
 
(31,463
)
 
47,220

 
31,149

 
32,890

 
(17,599
)
 
93,491

Investment tax credit adjustments - net
 
(1,227
)
 
(5,337
)
 
(1,737
)
 
(138
)
 
(914
)
 
(3,867
)
Income taxes
 

$40,541

 

$178,671

 

$61,872

 

$25,190

 

$37,250

 

$53,077


2014
 
Entergy
Arkansas
 
Entergy
Louisiana
 
Entergy
Mississippi
 
Entergy
New Orleans
 
Entergy
Texas
 
System
Energy
 
 
(In Thousands)
Current:
 
 
 
 
 
 
 
 
 
 
 
 
Federal
 

($34,258
)
 

($44,909
)
 

$8,103

 

($1,428
)
 

$48,610

 

$19,908

State
 
(678
)
 
(1,191
)
 
7,474

 
510

 
4,877

 
15,379

Total
 
(34,936
)
 
(46,100
)
 
15,577

 
(918
)
 
53,487

 
35,287

Deferred and non-current - net
 
119,841

 
236,794

 
42,305

 
14,592

 
(2,418
)
 
53,501

Investment tax credit adjustments - net
 
(1,276
)
 
(5,642
)
 
(2,172
)
 
(224
)
 
(1,425
)
 
(5,478
)
Income taxes
 

$83,629

 

$185,052

 

$55,710

 

$13,450

 

$49,644

 

$83,310


2013
 
Entergy
Arkansas
 
Entergy
Louisiana
 
Entergy
Mississippi
 
Entergy
New Orleans
 
Entergy
Texas
 
System
Energy
 
 
(In Thousands)
Current:
 
 
 
 
 
 
 
 
 
 
 
 
Federal
 

($13,574
)
 

($18,797
)
 

$2,498

 

$14,823

 

$37,199

 

($6,199
)
State
 
6,122

 
(15,631
)
 
4,849

 
(1,267
)
 
(843
)
 
15,845

Total
 
(7,452
)
 
(34,428
)
 
7,347

 
13,556

 
36,356

 
9,646

Deferred and non-current - net
 
101,253

 
179,036

 
41,150

 
(11,033
)
 
(4,639
)
 
60,614

Investment tax credit adjustments - net
 
(2,014
)
 
(5,912
)
 
1,260

 
(246
)
 
(1,609
)
 
(1,407
)
Income taxes
 

$91,787

 

$138,696

 

$49,757

 

$2,277

 

$30,108

 

$68,853



Total income taxes for Entergy Corporation and Subsidiaries differ from the amounts computed by applying the statutory income tax rate to income before income taxes.  The reasons for the differences for the years 2015, 2014, and 2013 are:
 
2015
 
2014
 
2013
 
(In Thousands)
Net income (loss) attributable to Entergy Corporation

($176,562
)
 

$940,721

 

$711,902

Preferred dividend requirements of subsidiaries
19,828

 
19,536

 
18,670

Consolidated net income (loss)
(156,734
)
 
960,257

 
730,572

Income taxes
(642,927
)
 
589,597

 
225,981

Income (loss) before income taxes

($799,661
)
 

$1,549,854

 

$956,553

Computed at statutory rate (35%)

($279,881
)
 

$542,449

 

$334,794

Increases (reductions) in tax resulting from:
 

 
 

 
 

State income taxes net of federal income tax effect
29,944

 
44,708

 
13,599

Regulatory differences - utility plant items
32,089

 
39,321

 
32,324

Equity component of AFUDC
(18,191
)
 
(21,108
)
 
(22,356
)
Amortization of investment tax credits
(11,136
)
 
(12,211
)
 
(13,535
)
Flow-through / permanent differences
(7,872
)
 
(18,003
)
 
(301
)
Net-of-tax regulatory liability

 

 
(2,899
)
New York tax law change (a)

 
(21,500
)
 

Louisiana business combination
(333,655
)
 

 

Termination of business reorganization

 

 
(27,192
)
Provision for uncertain tax positions (b)
(56,683
)
 
32,573

 
(59,249
)
Valuation allowance

 

 
(31,573
)
Other - net
2,458

 
3,368

 
2,369

Total income taxes as reported

($642,927
)
 

$589,597

 

$225,981

Effective Income Tax Rate
80.4
%
 
38.0
%
 
23.6
%


(a)
In March 2014, New York enacted legislation that substantially modifies various aspects of New York tax law. The most significant effect of the legislation for Entergy is the adoption of full water’s-edge unitary combined reporting, meaning that all of Entergy’s domestic entities will be included in New York’s combined filing group. The effect of the tax law change resulted in a deferred state income tax reduction of approximately $21.5 million as shown in the table above.
(b)
See “Income Tax Audits - 2008-2009 IRS Audit” below for discussion of the most significant items for 2015 and 2013.

Total income taxes for the Registrant Subsidiaries differ from the amounts computed by applying the statutory income tax rate to income before taxes.  The reasons for the differences for the years 2015, 2014, and 2013 are:
2015
 
Entergy
Arkansas
 
Entergy
Louisiana
 
Entergy
Mississippi
 
Entergy
New Orleans
 
Entergy
Texas
 
System
Energy
 
 
(In Thousands)
Net income
 

$74,272

 

$446,639

 

$92,708

 

$44,925

 

$69,625

 

$111,318

Income taxes
 
40,541

 
178,671

 
61,872

 
25,190

 
37,250

 
53,077

Pretax income
 

$114,813

 

$625,310

 

$154,580

 

$70,115

 

$106,875

 

$164,395

Computed at statutory rate (35%)
 

$40,185

 

$218,859

 

$54,103

 

$24,540

 

$37,406

 

$57,538

Increases (reductions) in tax resulting from:
 
 
 
 

 
 

 
 

 
 

 
 

State income taxes net of federal income tax effect
 
6,643

 
23,650

 
5,219

 
2,887

 
1,621

 
6,403

Regulatory differences - utility plant items
 
7,299

 
3,013

 
2,383

 
2,201

 
3,703

 
12,167

Equity component of AFUDC
 
(4,979
)
 
(5,420
)
 
(1,083
)
 
(451
)
 
(1,987
)
 
(2,973
)
Amortization of investment tax credits
 
(1,201
)
 
(5,252
)
 
(160
)
 
(111
)
 
(900
)
 
(3,476
)
Flow-through / permanent differences
 
(4,062
)
 
2,460

 
431

 
(4,539
)
 
530

 
618

Non-taxable dividend income
 

 
(44,658
)
 

 

 

 

Provision for uncertain tax positions (a)
 
(3,978
)
 
(15,377
)
 
756

 
525

 
(3,365
)
 
(17,313
)
Other - net
 
634

 
1,396

 
223

 
138

 
242

 
113

Total income taxes
 

$40,541

 

$178,671

 

$61,872

 

$25,190

 

$37,250

 

$53,077

Effective Income Tax Rate
 
35.3
%
 
28.6
%
 
40.0
%
 
35.9
%
 
34.9
%
 
32.3
%


(a)
See “Income Tax Audits - 2008-2009 IRS Audit” below for discussion of the most significant items for Entergy Louisiana and System Energy.

2014
 
Entergy
Arkansas
 
Entergy
Louisiana
 
Entergy
Mississippi
 
Entergy
New Orleans
 
Entergy
Texas
 
System
Energy
 
 
(In Thousands)
Net income
 

$121,392

 

$446,022

 

$74,821

 

$31,030

 

$74,804

 

$96,334

Income taxes
 
83,629

 
185,052

 
55,710

 
13,450

 
49,644

 
83,310

Pretax income
 

$205,021

 

$631,074

 

$130,531

 

$44,480

 

$124,448

 

$179,644

Computed at statutory rate (35%)
 

$71,757

 

$220,876

 

$45,686

 

$15,568

 

$43,557

 

$62,875

Increases (reductions) in tax resulting from:
 
 

 
 

 
 

 
 

 
 

 
 

State income taxes net of federal income tax effect
 
9,591

 
11,666

 
5,180

 
1,562

 
3,221

 
6,877

Regulatory differences - utility plant items
 
8,653

 
7,487

 
4,448

 
777

 
4,165

 
13,791

Equity component of AFUDC
 
(2,533
)
 
(14,612
)
 
(833
)
 
(320
)
 
(1,035
)
 
(1,774
)
Amortization of investment tax credits
 
(1,251
)
 
(5,594
)
 
(260
)
 
(218
)
 
(1,412
)
 
(3,476
)
Flow-through / permanent differences
 
(5,082
)
 
(225
)
 
555

 
(4,458
)
 
393

 
(327
)
Non-taxable dividend income
 

 
(41,255
)
 

 

 

 

Provision for uncertain tax positions
 
1,881

 
5,336

 
718

 
405

 
522

 
5,235

Other - net
 
613

 
1,373

 
216

 
134

 
233

 
109

Total income taxes
 

$83,629

 

$185,052

 

$55,710

 

$13,450

 

$49,644

 

$83,310

Effective Income Tax Rate
 
40.8
%
 
29.3
%
 
42.7
%
 
30.2
%
 
39.9
%
 
46.4
%


2013
 
Entergy
Arkansas
 
Entergy
Louisiana
 
Entergy
Mississippi
 
Entergy
New Orleans
 
Entergy
Texas
 
System
Energy
 
 
(In Thousands)
Net income
 

$161,948

 

$414,126

 

$82,159

 

$12,608

 

$57,881

 

$113,664

Income taxes
 
91,787

 
138,696

 
49,757

 
2,277

 
30,108

 
68,853

Pretax income
 

$253,735

 

$552,822

 

$131,916

 

$14,885

 

$87,989

 

$182,517

Computed at statutory rate (35%)
 

$88,807

 

$193,488

 

$46,171

 

$5,210

 

$30,796

 

$63,881

Increases (reductions) in tax resulting from:
 
 

 
 

 
 

 
 

 
 

 
 

State income taxes net of federal income tax effect
 
10,954

 
19,084

 
4,564

 
1,116

 
(897
)
 
5,900

Regulatory differences - utility plant items
 
7,938

 
7,005

 
2,603

 
453

 
3,256

 
11,070

Equity component of AFUDC
 
(3,820
)
 
(13,100
)
 
(764
)
 
(322
)
 
(1,626
)
 
(2,724
)
Amortization of investment tax credits
 
(1,989
)
 
(5,864
)
 
(260
)
 
(216
)
 
(1,596
)
 
(3,476
)
Flow-through / permanent differences
 
2,540

 
3,646

 
1,702

 
(4,402
)
 
2,467

 
(491
)
Net-of-tax regulatory liability
 

 
(2,899
)
 

 

 

 

Termination of business organization
 
(6,753
)
 
(7,453
)
 
(4,177
)
 
(501
)
 
(3,542
)
 
(13
)
Non-taxable dividend income
 

 
(36,953
)
 

 

 

 

Provision for uncertain tax positions (a)
 
(6,527
)
 
(18,645
)
 
(326
)
 
795

 
1,027

 
(5,353
)
Other - net
 
637

 
387

 
244

 
144

 
223

 
59

Total income taxes
 

$91,787

 

$138,696

 

$49,757

 

$2,277

 

$30,108

 

$68,853

Effective Income Tax Rate
 
36.2
%
 
25.1
%
 
37.7
%
 
15.3
%
 
34.2
%
 
37.7
%


(a)
See “Income Tax Audits - 2008-2009 IRS Audit” below for discussion of the most significant items for Entergy Louisiana and System Energy.

Significant components of accumulated deferred income taxes and taxes accrued for Entergy Corporation and Subsidiaries as of December 31, 2015 and 2014 are as follows:
 
 
2015
 
2014
 
(In Thousands)
Deferred tax liabilities:
 
 
 
Plant basis differences - net

($6,804,225
)
 

($8,128,096
)
Regulatory assets
(646,392
)
 
(922,161
)
Nuclear decommissioning trusts
(1,254,463
)
 
(1,248,737
)
Pension, net funding
(365,111
)
 
(324,881
)
Combined unitary state taxes
(45,078
)
 
(162,340
)
Power purchase agreements

 
(110,889
)
Other
(315,844
)
 
(500,424
)
Total
(9,431,113
)
 
(11,397,528
)
Deferred tax assets:
 

 
 

Nuclear decommissioning liabilities
828,983

 
874,493

Regulatory liabilities
284,432

 
458,230

Pension and other post-employment benefits
525,524

 
586,455

Sale and leaseback
139,720

 
153,308

Compensation
69,432

 
74,692

Accumulated deferred investment tax credit
95,248

 
100,442

Provision for allowances and contingencies
188,282

 
160,551

Power purchase agreements
38,401

 

Net operating loss carryforwards
360,188

 
457,758

Capital losses and miscellaneous tax credits
11,075

 
12,146

Valuation allowance
(91,532
)
 
(27,387
)
Other
68,204

 
58,334

Total
2,517,957

 
2,909,022

Non-current accrued taxes (including unrecognized tax benefits)
(1,338,806
)
 
(606,560
)
Accumulated deferred income taxes and taxes accrued

($8,251,962
)
 

($9,095,066
)


Entergy’s estimated tax attributes carryovers and their expiration dates as of December 31, 2015 are as follows:
Carryover Description
 
Carryover Amount
 
Year(s) of expiration
 
 
 
 
 
Federal net operating losses
 
$3.6 billion
 
2023-2035
State net operating losses
 
$5.2 billion
 
2016-2035
Miscellaneous federal and state credits
 
$77.9 million
 
2016-2035


As a result of the accounting for uncertain tax positions, the amount of the deferred tax assets reflected in the financial statements is less than the amount of the tax effect of the federal and state net operating loss carryovers, tax credit carryovers, and other tax attributes reflected on income tax returns. Because it is more likely than not that the benefit from certain state net operating loss carryovers will not be utilized, valuation allowances of $46 million as of December 31, 2015 and $21 million as of December 31, 2014 have been provided on the deferred tax assets relating to these state net operating loss carryovers. Additionally, valuation allowances totaling $45.5 million as of December 31, 2015 have been provided on deferred tax assets related to state jurisdictions in which Entergy does not currently expect to be able to utilize separate company tax return losses, preventing realization of such deferred tax assets.
Significant components of accumulated deferred income taxes and taxes accrued for the Registrant Subsidiaries as of December 31, 2015 and 2014 are as follows:
2015
Entergy
Arkansas
 
Entergy
Louisiana
 
Entergy
Mississippi
 
Entergy
New Orleans
 
Entergy
Texas
 
System
Energy
 
(In Thousands)
Deferred tax liabilities:
 
 
 
 
 
 
 
 
 
 
 
Plant basis differences - net

($1,710,444
)
 

($2,041,968
)
 

($781,427
)
 

($167,294
)
 

($778,270
)
 

($611,745
)
Regulatory assets
(108,422
)
 
(254,316
)
 
(24,918
)
 
(39,451
)
 
(172,117
)
 
(46,990
)
Nuclear decommissioning trusts
(121,326
)
 
(99,980
)
 

 

 

 
(68,370
)
Pension, net funding
(107,073
)
 
(109,709
)
 
(30,901
)
 
(14,459
)
 
(28,001
)
 
(25,791
)
Deferred fuel
(7,647
)
 
(2,513
)
 
(684
)
 
(175
)
 
2,050

 
(18
)
Other
(38,683
)
 
(86,275
)
 
(5,625
)
 
(12,253
)
 
(10,109
)
 
(22,478
)
Total
(2,093,595
)
 
(2,594,761
)
 
(843,555
)
 
(233,632
)
 
(986,447
)
 
(775,392
)
Deferred tax assets:
 

 
 

 
 

 
 

 
 

 
 

Regulatory liabilities
18,369

 
215,154

 
7,787

 
20,888

 
7,307

 
14,927

Nuclear decommissioning liabilities
109,962

 
49,333

 

 

 

 
39,420

Pension and other post-employment benefits
(20,420
)
 
149,680

 
(6,628
)
 
(8,939
)
 
(16,703
)
 
(1,037
)
Sale and leaseback

 
37,236

 

 

 

 
102,484

Accumulated deferred investment tax credit
14,320

 
56,635

 
1,777

 
290

 
4,842

 
17,385

Provision for allowances and contingencies
1,024

 
123,007

 
18,735

 
33,843

 
7,266

 
134

Power purchase agreements
(1,279
)
 
13,840

 
1,901

 
13

 
575

 

Unbilled/deferred revenues
9,815

 
(32,365
)
 
7,154

 
2,126

 
10,851

 

Compensation
1,842

 
4,182

 
601

 
880

 
4,496

 

Net operating loss carryforwards

 
90,241

 

 

 

 

Other
128

 
21,982

 
1,995

 
316

 
1,672

 

Total
133,761

 
728,925

 
33,322

 
49,417

 
20,306

 
173,313

Non-current accrued taxes (including unrecognized tax benefits)
(22,978
)
 
(641,120
)
 
(402
)
 
(29,846
)
 
(40,693
)
 
(416,996
)
Accumulated deferred income taxes and taxes accrued

($1,982,812
)
 

($2,506,956
)
 

($810,635
)
 

($214,061
)
 

($1,006,834
)
 

($1,019,075
)
2014
 
Entergy
Arkansas
 
Entergy
Louisiana
 
Entergy
Mississippi
 
Entergy
New Orleans
 
Entergy
Texas
 
System
Energy
 
 
(In Thousands)
Deferred tax liabilities:
 
 
 
 
 
 
 
 
 
 
 
 
Plant basis differences - net
 

($1,657,503
)
 

($2,748,852
)
 

($753,576
)
 

($186,153
)
 

($771,135
)
 

($668,779
)
Regulatory assets
 
(198,662
)
 
(380,719
)
 
(30,114
)
 

 
(202,402
)
 
(110,087
)
Nuclear decommissioning trusts
 
(130,524
)
 
(106,162
)
 

 

 

 
(74,063
)
Pension, net funding
 
(93,355
)
 
(99,593
)
 
(27,861
)
 
(13,285
)
 
(25,616
)
 
(23,440
)
Deferred fuel
 
(82,050
)
 
(3,534
)
 
(5,303
)
 
(407
)
 
2,045

 
(120
)
Power purchase agreements
 
(17,073
)
 
(67,083
)
 
2,129

 
13

 
847

 

Other
 
(33,827
)
 
(84,282
)
 
(11,423
)
 
(11,500
)
 
(22,546
)
 
(19,802
)
Total
 
(2,212,994
)
 
(3,490,225
)
 
(826,148
)
 
(211,332
)
 
(1,018,807
)
 
(896,291
)
Deferred tax assets:
 
 

 
 

 
 

 
 

 
 

 
 

Regulatory liabilities
 
145,466

 
181,601

 
7,214

 
29,580

 
4,079

 
90,290

Nuclear decommissioning liabilities
 
(43,134
)
 
146,138

 

 

 

 
(62,571
)
Pension and other post-employment benefits
 
(17,534
)
 
158,661

 
(7,288
)
 
(7,504
)
 
(15,053
)
 
(1,413
)
Sale and leaseback
 

 
45,136

 

 

 

 
108,172

Accumulated deferred investment tax credit
 
14,791

 
58,863

 
2,436

 
332

 
5,158

 
18,862

Provision for allowances and contingencies
 
(7,149
)
 
125,805

 
19,590

 
10,986

 
8,017

 
133

Unbilled/deferred revenues
 
12,322

 
(25,016
)
 
12,956

 
3,395

 
11,573

 

Compensation
 
2,085

 
158

 
(846
)
 
475

 
4,155

 

Net operating loss carryforwards
 
105,063

 
241,803

 

 

 

 

Capital losses and miscellaneous tax credits
 

 

 
3,504

 

 

 

Other
 
258

 
15,508

 
5,887

 
2,891

 
3,850

 
2,000

Total
 
212,168

 
948,657

 
43,453

 
40,155

 
21,779

 
155,473

Non-current accrued taxes (including unrecognized tax benefits)
 
9,367

 
(412,508
)
 
(12,481
)
 
(19,502
)
 
(48,921
)
 
(81,528
)
Accumulated deferred income taxes and taxes accrued
 

($1,991,459
)
 

($2,954,076
)
 

($795,176
)
 

($190,679
)
 

($1,045,949
)
 

($822,346
)


The Registrant Subsidiaries’ estimated tax attributes carryovers and their expiration dates as of December 31, 2015 are as follows:
 
 
 
Entergy
Arkansas
 
 
Entergy
Louisiana
 
 
Entergy
Mississippi
 
Entergy
New Orleans
 
 
Entergy
Texas
 
 
System
Energy
 
 
 
 
 
 
 
 
 
 
 
 
 
Federal net operating losses
 
$7 million
 
$2.4 billion
 
 
 
 
$242 million
Year(s) of expiration
 
2030-2035
 
2035
 
N/A
 
N/A
 
N/A
 
2030-2035
 
 
 
 
 
 
 
 
 
 
 
 
 
State net operating losses
 
 
$2.5 billion
 
 
$6 million
 
 
$833 million
Year(s) of expiration
 
N/A
 
2035
 
N/A
 
2032
 
N/A
 
2035
 
 
 
 
 
 
 
 
 
 
 
 
 
Misc. federal credits
 
$1 million
 
 
$1 million
 
 
 
$1 million
Year(s) of expiration
 
2029-2033
 
N/A
 
2029-2034
 
N/A
 
N/A
 
2029-2033
 
 
 
 
 
 
 
 
 
 
 
 
 
State credits
 
 
 
 
 
$3.3 million
 
$6 million
Year(s) of expiration
 
N/A
 
N/A
 
N/A
 
N/A
 
2026
 
2017-2020


As a result of the accounting for uncertain tax positions, the amount of the deferred tax assets reflected in the financial statements is less than the amount of the tax effect of the federal and state net operating loss carryovers and tax credit carryovers.

Unrecognized tax benefits

Accounting standards establish a “more-likely-than-not” recognition threshold that must be met before a tax benefit can be recognized in the financial statements.  If a tax deduction is taken on a tax return, but does not meet the more-likely-than-not recognition threshold, an increase in income tax liability, above what is payable on the tax return, is required to be recorded.  A reconciliation of Entergy’s beginning and ending amount of unrecognized tax benefits is as follows:
 
2015
 
2014
 
2013
 
(In Thousands)
Gross balance at January 1

$4,736,785

 

$4,593,224

 

$4,170,403

Additions based on tax positions related to the current year
1,850,705

 
348,543

 
162,338

Additions for tax positions of prior years
59,815

 
11,637

 
410,108

Reductions for tax positions of prior years (a)
(3,966,535
)
 
(213,401
)
 
(103,360
)
Settlements
(68,227
)
 

 
(43,620
)
Lapse of statute of limitations
(958
)
 
(3,218
)
 
(2,645
)
Gross balance at December 31
2,611,585

 
4,736,785

 
4,593,224

Offsets to gross unrecognized tax benefits:
 

 
 

 
 

Credit and loss carryovers
(1,264,483
)
 
(4,295,643
)
 
(4,400,498
)
Unrecognized tax benefits net of unused tax attributes and payments (b)

$1,347,102

 

$441,142

 

$192,726



(a)
The primary reduction is related to the nuclear decommissioning costs treatment discussed in “Income Tax Audits - 2008-2009 IRS Audit” below.
(b)
Potential tax liability above what is payable on tax returns

The balances of unrecognized tax benefits include $955 million, $516 million, and $176 million as of December 31, 2015, 2014, and 2013, respectively, which, if recognized, would lower the effective income tax rates.  Because of the effect of deferred tax accounting, the remaining balances of unrecognized tax benefits of $1.657 billion, $4.221 billion, and $4.417 billion as of December 31, 2015, 2014, and 2013, respectively, if disallowed, would not affect the annual effective income tax rate but would accelerate the payment of cash to the taxing authority to an earlier period.

Entergy accrues interest expense, if any, related to unrecognized tax benefits in income tax expense.  Entergy’s December 31, 2015, 2014, and 2013 accrued balance for the possible payment of interest is approximately $27 million, $127 million, and $96.4 million, respectively.

A reconciliation of the Registrant Subsidiaries’ beginning and ending amount of unrecognized tax benefits for 2015, 2014, and 2013 is as follows:
2015
 
Entergy
Arkansas
 
Entergy
Louisiana
 
Entergy
Mississippi
 
Entergy
New Orleans
 
Entergy
Texas
 
System
Energy
 
 
(In Thousands)
Gross balance at January 1, 2015
 

$362,912

 

$1,205,929

 

$20,144

 

$53,763

 

$17,264

 

$258,242

Additions based on tax positions related to the current year (a)
 
2,196

 
1,367,058

 
566

 
472

 
657

 
472,304

Additions for tax positions of prior years
 
1,057

 
7,992

 
8,140

 
48

 
2,914

 
913

Reductions for tax positions of prior years
 
(340,720
)
 
(859,430
)
 

 
(386
)
 
(3,981
)
 
(253,141
)
Settlements
 

 
(30,888
)
 
(9,368
)
 

 
(3,392
)
 

Gross balance at December 31, 2015
 
25,445

 
1,690,661

 
19,482

 
53,897

 
13,462

 
478,318

Offsets to gross unrecognized tax benefits:
 
 

 
 

 
 

 
 

 
 

 
 

Loss carryovers
 
(3,613
)
 
(893,764
)
 
(1,016
)
 
(506
)
 
(276
)
 
(133,611
)
Unrecognized tax benefits net of unused tax attributes and payments
 

$21,832

 

$796,897

 

$18,466

 

$53,391

 

$13,186

 

$344,707



(a)
The primary addition for Entergy Louisiana and System Energy is related to the nuclear decommissioning costs treatment discussed in “Other Tax Matters” below.

2014
 
Entergy
Arkansas
 
Entergy
Louisiana
 
Entergy
Mississippi
 
Entergy
New Orleans
 
Entergy
Texas
 
System
Energy
 
 
(In Thousands)
Gross balance at January 1, 2014
 

$347,713

 

$1,076,680

 

$16,186

 

$51,679

 

$13,017

 

$265,185

Additions based on tax positions related to the current year
 
14,511

 
151,249

 
3,928

 
2,235

 
4,225

 
2,744

Additions for tax positions of prior years
 
1,767

 
6,924

 
319

 
37

 
303

 
566

Reductions for tax positions of prior years
 
(1,079
)
 
(28,924
)
 
(289
)
 
(188
)
 
(267
)
 
(10,253
)
Settlements
 

 

 

 

 
(14
)
 

Gross balance at December 31, 2014
 
362,912

 
1,205,929

 
20,144

 
53,763

 
17,264

 
258,242

Offsets to gross unrecognized tax benefits:
 
 

 
 

 
 

 
 

 
 

 
 

Loss carryovers
 
(361,043
)
 
(739,988
)
 
(6,992
)
 
(20,735
)
 
(241
)
 
(163,124
)
Unrecognized tax benefits net of unused tax attributes and payments
 

$1,869

 

$465,941

 

$13,152

 

$33,028

 

$17,023

 

$95,118


2013
 
Entergy
Arkansas
 
Entergy
Louisiana
 
Entergy
Mississippi
 
Entergy
New Orleans
 
Entergy
Texas
 
System
Energy
 
 
(In Thousands)
Gross balance at January 1, 2013
 

$344,669

 

$1,002,394

 

$16,841

 

$52,018

 

$13,954

 

$260,346

Additions based on tax positions related to the current year
 
6,427

 
17,887

 
957

 
583

 
2,170

 
4,170

Additions for tax positions of prior years
 
1,228

 
125,214

 
401

 
3,506

 
587

 
8,391

Reductions for tax positions of prior years
 
(3,943
)
 
(53,473
)
 
(1,941
)
 
(962
)
 
(4,186
)
 
(967
)
Settlements
 
(668
)
 
(15,342
)
 
(72
)
 
(3,466
)
 
492

 
(6,755
)
Gross balance at December 31, 2013
 
347,713

 
1,076,680

 
16,186

 
51,679

 
13,017

 
265,185

Offsets to gross unrecognized tax benefits:
 
 

 
 

 
 

 
 

 
 

 
 

Loss carryovers
 
(345,674
)
 
(747,756
)
 
(16,186
)
 
(22,078
)
 
(266
)
 
(225,286
)
Unrecognized tax benefits net of unused tax attributes and payments
 

$2,039

 

$328,924

 

$—

 

$29,601

 

$12,751

 

$39,899



The Registrant Subsidiaries’ balances of unrecognized tax benefits included amounts which, if recognized, would have reduced income tax expense as follows:
 
December 31,
 
2015
 
2014
 
2013
 
(In Millions)
Entergy Arkansas

$4.5

 

$2.6

 

$0.6

Entergy Louisiana

$692.7

 

$267.3

 

$131.9

Entergy Mississippi

$8.1

 

$3.9

 

$3.9

Entergy New Orleans

$50.7

 

$50.7

 

$—

Entergy Texas

$5.2

 

$10.5

 

$10.1

System Energy

$0.7

 

$3.7

 

$3.3



The Registrant Subsidiaries accrue interest and penalties related to unrecognized tax benefits in income tax expense.  Penalties have not been accrued.  Accrued balances for the possible payment of interest are as follows:
 
December 31,
 
2015
 
2014
 
2013
 
(In Millions)
Entergy Arkansas

$1.3

 

$17.0

 

$15.2

Entergy Louisiana

$9.3

 

$22.2

 

$18.0

Entergy Mississippi

$0.4

 

$2.8

 

$2.1

Entergy New Orleans

$1.8

 

$1.3

 

$0.9

Entergy Texas

$1.2

 

$1.0

 

$0.8

System Energy

$0.7

 

$23.8

 

$19.0



Income Tax Audits

Entergy and its subsidiaries file U.S. federal and various state and foreign income tax returns.  IRS examinations are complete for years before 2010. All state taxing authorities’ examinations are completed for years before 2009.

2006-2007 IRS Audit

In the first quarter 2015, the IRS finalized tax and interest computations from the 2006-2007 audit that resulted in a reversal of Entergy’s provision for uncertain tax positions related to accrued interest of approximately $20 million, including decreases of approximately $4 million for Entergy Arkansas, $11 million for Entergy Louisiana, and $1 million for System Energy.

2008-2009 IRS Audit

In the fourth quarter 2009, Entergy filed Applications for Change in Accounting Method (the “2009 CAM”) for tax purposes with the IRS for certain costs under Section 263A of the Internal Revenue Code.  In the Applications, Entergy proposed to treat the nuclear decommissioning liability associated with the operation of its nuclear power plants as a production cost properly includable in cost of goods sold.  The effect of the 2009 CAM was a $5.7 billion reduction in 2009 taxable income.  The 2009 CAM was adjusted to $9.3 billion in 2012.

In the fourth quarter 2012 the IRS disallowed the reduction to 2009 taxable income related to the 2009 CAM.  In the third quarter 2013, the Internal Revenue Service issued its RAR for the tax years 2008-2009. As a result of the issuance of this RAR, Entergy and the IRS resolved all of the 2008-2009 issues described above except for the 2009 CAM. Entergy disagreed with the IRS’s disallowance of the 2009 CAM and filed a protest with the IRS Appeals Division in October 2013.

In August 2015, Entergy and the IRS agreed on the treatment of the 2009 position regarding nuclear decommissioning liabilities from the 2008-2009 audit. The agreement provides that Entergy is entitled to deduct approximately $118 million of the $9.3 billion claimed in 2009. The agreement effectively settled all matters pertaining to the 2009 tax year and increased Entergy’s 2009 federal income tax liability by $2.4 million.

2010-2011 IRS Audit

The IRS examination of the 2010 and 2011 years is ongoing and the audit field work is expected to be completed by the end of the first quarter of 2016. The IRS has not issued any significant notices of proposed adjustments other than for the decommissioning liability position discussed above. The Revenue Agent’s Report is expected to be received shortly after the completion of field work.

Other Tax Matters

Entergy regularly negotiates with the IRS to achieve settlements.  The resolution of audit issues could result in significant changes to the amounts of unrecognized tax benefits in the next twelve months.

In September 2013 the U.S. Treasury Department and the IRS issued final regulations that provide guidance on the deductibility and capitalization of costs incurred associated with tangible property. Entergy and the Registrant Subsidiaries filed with the IRS an automatic application for change in accounting method which is in compliance with the final regulations and the safe harbor provisions of the relevant IRS Revenue Procedures. Entergy estimates that the effect of this accounting method change will result in a net increase to Entergy’s taxable income of approximately $585 million, which will be recognized generally over a four year period beginning with the tax year ended 2014. The adoption of the final regulations and safe harbor method results in approximate changes in the Registrant Subsidiaries taxable income as follows: an increase of $177 million for Entergy Arkansas, an increase of $78 million for Entergy Louisiana, an increase of $26 million for Entergy Mississippi, an increase of $183 million for Entergy Texas, a decrease of $2 million for Entergy New Orleans, and an increase of $22 million for System Energy.

In October 2015 two of Entergy’s Louisiana utilities, Entergy Gulf States Louisiana and Entergy Louisiana, combined their businesses into a legal entity which is identified as Entergy Louisiana herein. Entergy Louisiana maintained a carryover tax basis in the assets received. Additionally, the tax consequences provided for an increase in tax basis as well. To the extent that this increase in tax basis will provide additional tax depreciation, Entergy recorded a deferred tax asset and current tax expense resulting in a net increase in tax basis of approximately $334 million and Entergy Louisiana obtained a corresponding deferred tax asset. Consistent with the terms of an agreement with the LPSC, electric customers of Entergy Louisiana will realize customer credits associated with the business combination. Accordingly, in October 2015, Entergy recorded a regulatory liability of $107 million ($66 million net-of-tax) which partially offsets the effect of the aforementioned deferred tax asset. The deferred tax asset and the regulatory liability, net-of-tax, increased Entergy Louisiana’s member’s equity by $268 million. See Note 2 to the financial statements for further discussion of the business combination.

In the fourth quarter 2015, System Energy and Entergy Louisiana adopted a new method of accounting for income tax purposes in which the companies’ nuclear decommissioning costs will be treated as production costs of electricity includable in cost of goods sold. The new method results in a reduction of taxable income of $1.2 billion for System Energy and $2.2 billion for Entergy Louisiana.

The Protecting Americans from Tax Hikes Act of 2015 was enacted in December 2015. The most significant provisions affecting Entergy and the Registrant Subsidiaries were a five-year extension of bonus depreciation and permanent extension of the research and experimentation tax credit. The effect of the bonus depreciation extension on 2015 increased Entergy’s tax net operating loss.
Entergy Louisiana [Member]  
Income Taxes
INCOME TAXES (Entergy Corporation, Entergy Arkansas, Entergy Louisiana, Entergy Mississippi, Entergy New Orleans, Entergy Texas, and System Energy)

Income taxes for 2015, 2014, and 2013 for Entergy Corporation and Subsidiaries consist of the following:
 
2015
 
2014
 
2013
 
(In Thousands)
Current:
 
 
 
 
 
Federal

$77,166

 

$90,061

 

$88,291

Foreign
97

 
90

 
101

State
157,829

 
(12,637
)
 
20,584

Total
235,092

 
77,514

 
108,976

Deferred and non-current - net
(864,799
)
 
528,326

 
126,935

Investment tax credit adjustments - net
(13,220
)
 
(16,243
)
 
(9,930
)
Income taxes

($642,927
)
 

$589,597

 

$225,981



Income taxes for 2015, 2014, and 2013 for Entergy’s Registrant Subsidiaries consist of the following:
2015
 
Entergy
Arkansas
 
Entergy
Louisiana
 
Entergy
Mississippi
 
Entergy
New Orleans
 
Entergy
Texas
 
System
Energy
 
 
(In Thousands)
Current:
 
 
 
 
 
 
 
 
 
 
 
 
Federal
 

$66,966

 

$101,382

 

$25,628

 

($9,346
)
 

$53,313

 

($63,302
)
State
 
6,265

 
35,406

 
6,832

 
1,784

 
2,450

 
26,755

Total
 
73,231

 
136,788

 
32,460

 
(7,562
)
 
55,763

 
(36,547
)
Deferred and non-current - net
 
(31,463
)
 
47,220

 
31,149

 
32,890

 
(17,599
)
 
93,491

Investment tax credit adjustments - net
 
(1,227
)
 
(5,337
)
 
(1,737
)
 
(138
)
 
(914
)
 
(3,867
)
Income taxes
 

$40,541

 

$178,671

 

$61,872

 

$25,190

 

$37,250

 

$53,077


2014
 
Entergy
Arkansas
 
Entergy
Louisiana
 
Entergy
Mississippi
 
Entergy
New Orleans
 
Entergy
Texas
 
System
Energy
 
 
(In Thousands)
Current:
 
 
 
 
 
 
 
 
 
 
 
 
Federal
 

($34,258
)
 

($44,909
)
 

$8,103

 

($1,428
)
 

$48,610

 

$19,908

State
 
(678
)
 
(1,191
)
 
7,474

 
510

 
4,877

 
15,379

Total
 
(34,936
)
 
(46,100
)
 
15,577

 
(918
)
 
53,487

 
35,287

Deferred and non-current - net
 
119,841

 
236,794

 
42,305

 
14,592

 
(2,418
)
 
53,501

Investment tax credit adjustments - net
 
(1,276
)
 
(5,642
)
 
(2,172
)
 
(224
)
 
(1,425
)
 
(5,478
)
Income taxes
 

$83,629

 

$185,052

 

$55,710

 

$13,450

 

$49,644

 

$83,310


2013
 
Entergy
Arkansas
 
Entergy
Louisiana
 
Entergy
Mississippi
 
Entergy
New Orleans
 
Entergy
Texas
 
System
Energy
 
 
(In Thousands)
Current:
 
 
 
 
 
 
 
 
 
 
 
 
Federal
 

($13,574
)
 

($18,797
)
 

$2,498

 

$14,823

 

$37,199

 

($6,199
)
State
 
6,122

 
(15,631
)
 
4,849

 
(1,267
)
 
(843
)
 
15,845

Total
 
(7,452
)
 
(34,428
)
 
7,347

 
13,556

 
36,356

 
9,646

Deferred and non-current - net
 
101,253

 
179,036

 
41,150

 
(11,033
)
 
(4,639
)
 
60,614

Investment tax credit adjustments - net
 
(2,014
)
 
(5,912
)
 
1,260

 
(246
)
 
(1,609
)
 
(1,407
)
Income taxes
 

$91,787

 

$138,696

 

$49,757

 

$2,277

 

$30,108

 

$68,853



Total income taxes for Entergy Corporation and Subsidiaries differ from the amounts computed by applying the statutory income tax rate to income before income taxes.  The reasons for the differences for the years 2015, 2014, and 2013 are:
 
2015
 
2014
 
2013
 
(In Thousands)
Net income (loss) attributable to Entergy Corporation

($176,562
)
 

$940,721

 

$711,902

Preferred dividend requirements of subsidiaries
19,828

 
19,536

 
18,670

Consolidated net income (loss)
(156,734
)
 
960,257

 
730,572

Income taxes
(642,927
)
 
589,597

 
225,981

Income (loss) before income taxes

($799,661
)
 

$1,549,854

 

$956,553

Computed at statutory rate (35%)

($279,881
)
 

$542,449

 

$334,794

Increases (reductions) in tax resulting from:
 

 
 

 
 

State income taxes net of federal income tax effect
29,944

 
44,708

 
13,599

Regulatory differences - utility plant items
32,089

 
39,321

 
32,324

Equity component of AFUDC
(18,191
)
 
(21,108
)
 
(22,356
)
Amortization of investment tax credits
(11,136
)
 
(12,211
)
 
(13,535
)
Flow-through / permanent differences
(7,872
)
 
(18,003
)
 
(301
)
Net-of-tax regulatory liability

 

 
(2,899
)
New York tax law change (a)

 
(21,500
)
 

Louisiana business combination
(333,655
)
 

 

Termination of business reorganization

 

 
(27,192
)
Provision for uncertain tax positions (b)
(56,683
)
 
32,573

 
(59,249
)
Valuation allowance

 

 
(31,573
)
Other - net
2,458

 
3,368

 
2,369

Total income taxes as reported

($642,927
)
 

$589,597

 

$225,981

Effective Income Tax Rate
80.4
%
 
38.0
%
 
23.6
%


(a)
In March 2014, New York enacted legislation that substantially modifies various aspects of New York tax law. The most significant effect of the legislation for Entergy is the adoption of full water’s-edge unitary combined reporting, meaning that all of Entergy’s domestic entities will be included in New York’s combined filing group. The effect of the tax law change resulted in a deferred state income tax reduction of approximately $21.5 million as shown in the table above.
(b)
See “Income Tax Audits - 2008-2009 IRS Audit” below for discussion of the most significant items for 2015 and 2013.

Total income taxes for the Registrant Subsidiaries differ from the amounts computed by applying the statutory income tax rate to income before taxes.  The reasons for the differences for the years 2015, 2014, and 2013 are:
2015
 
Entergy
Arkansas
 
Entergy
Louisiana
 
Entergy
Mississippi
 
Entergy
New Orleans
 
Entergy
Texas
 
System
Energy
 
 
(In Thousands)
Net income
 

$74,272

 

$446,639

 

$92,708

 

$44,925

 

$69,625

 

$111,318

Income taxes
 
40,541

 
178,671

 
61,872

 
25,190

 
37,250

 
53,077

Pretax income
 

$114,813

 

$625,310

 

$154,580

 

$70,115

 

$106,875

 

$164,395

Computed at statutory rate (35%)
 

$40,185

 

$218,859

 

$54,103

 

$24,540

 

$37,406

 

$57,538

Increases (reductions) in tax resulting from:
 
 
 
 

 
 

 
 

 
 

 
 

State income taxes net of federal income tax effect
 
6,643

 
23,650

 
5,219

 
2,887

 
1,621

 
6,403

Regulatory differences - utility plant items
 
7,299

 
3,013

 
2,383

 
2,201

 
3,703

 
12,167

Equity component of AFUDC
 
(4,979
)
 
(5,420
)
 
(1,083
)
 
(451
)
 
(1,987
)
 
(2,973
)
Amortization of investment tax credits
 
(1,201
)
 
(5,252
)
 
(160
)
 
(111
)
 
(900
)
 
(3,476
)
Flow-through / permanent differences
 
(4,062
)
 
2,460

 
431

 
(4,539
)
 
530

 
618

Non-taxable dividend income
 

 
(44,658
)
 

 

 

 

Provision for uncertain tax positions (a)
 
(3,978
)
 
(15,377
)
 
756

 
525

 
(3,365
)
 
(17,313
)
Other - net
 
634

 
1,396

 
223

 
138

 
242

 
113

Total income taxes
 

$40,541

 

$178,671

 

$61,872

 

$25,190

 

$37,250

 

$53,077

Effective Income Tax Rate
 
35.3
%
 
28.6
%
 
40.0
%
 
35.9
%
 
34.9
%
 
32.3
%


(a)
See “Income Tax Audits - 2008-2009 IRS Audit” below for discussion of the most significant items for Entergy Louisiana and System Energy.

2014
 
Entergy
Arkansas
 
Entergy
Louisiana
 
Entergy
Mississippi
 
Entergy
New Orleans
 
Entergy
Texas
 
System
Energy
 
 
(In Thousands)
Net income
 

$121,392

 

$446,022

 

$74,821

 

$31,030

 

$74,804

 

$96,334

Income taxes
 
83,629

 
185,052

 
55,710

 
13,450

 
49,644

 
83,310

Pretax income
 

$205,021

 

$631,074

 

$130,531

 

$44,480

 

$124,448

 

$179,644

Computed at statutory rate (35%)
 

$71,757

 

$220,876

 

$45,686

 

$15,568

 

$43,557

 

$62,875

Increases (reductions) in tax resulting from:
 
 

 
 

 
 

 
 

 
 

 
 

State income taxes net of federal income tax effect
 
9,591

 
11,666

 
5,180

 
1,562

 
3,221

 
6,877

Regulatory differences - utility plant items
 
8,653

 
7,487

 
4,448

 
777

 
4,165

 
13,791

Equity component of AFUDC
 
(2,533
)
 
(14,612
)
 
(833
)
 
(320
)
 
(1,035
)
 
(1,774
)
Amortization of investment tax credits
 
(1,251
)
 
(5,594
)
 
(260
)
 
(218
)
 
(1,412
)
 
(3,476
)
Flow-through / permanent differences
 
(5,082
)
 
(225
)
 
555

 
(4,458
)
 
393

 
(327
)
Non-taxable dividend income
 

 
(41,255
)
 

 

 

 

Provision for uncertain tax positions
 
1,881

 
5,336

 
718

 
405

 
522

 
5,235

Other - net
 
613

 
1,373

 
216

 
134

 
233

 
109

Total income taxes
 

$83,629

 

$185,052

 

$55,710

 

$13,450

 

$49,644

 

$83,310

Effective Income Tax Rate
 
40.8
%
 
29.3
%
 
42.7
%
 
30.2
%
 
39.9
%
 
46.4
%


2013
 
Entergy
Arkansas
 
Entergy
Louisiana
 
Entergy
Mississippi
 
Entergy
New Orleans
 
Entergy
Texas
 
System
Energy
 
 
(In Thousands)
Net income
 

$161,948

 

$414,126

 

$82,159

 

$12,608

 

$57,881

 

$113,664

Income taxes
 
91,787

 
138,696

 
49,757

 
2,277

 
30,108

 
68,853

Pretax income
 

$253,735

 

$552,822

 

$131,916

 

$14,885

 

$87,989

 

$182,517

Computed at statutory rate (35%)
 

$88,807

 

$193,488

 

$46,171

 

$5,210

 

$30,796

 

$63,881

Increases (reductions) in tax resulting from:
 
 

 
 

 
 

 
 

 
 

 
 

State income taxes net of federal income tax effect
 
10,954

 
19,084

 
4,564

 
1,116

 
(897
)
 
5,900

Regulatory differences - utility plant items
 
7,938

 
7,005

 
2,603

 
453

 
3,256

 
11,070

Equity component of AFUDC
 
(3,820
)
 
(13,100
)
 
(764
)
 
(322
)
 
(1,626
)
 
(2,724
)
Amortization of investment tax credits
 
(1,989
)
 
(5,864
)
 
(260
)
 
(216
)
 
(1,596
)
 
(3,476
)
Flow-through / permanent differences
 
2,540

 
3,646

 
1,702

 
(4,402
)
 
2,467

 
(491
)
Net-of-tax regulatory liability
 

 
(2,899
)
 

 

 

 

Termination of business organization
 
(6,753
)
 
(7,453
)
 
(4,177
)
 
(501
)
 
(3,542
)
 
(13
)
Non-taxable dividend income
 

 
(36,953
)
 

 

 

 

Provision for uncertain tax positions (a)
 
(6,527
)
 
(18,645
)
 
(326
)
 
795

 
1,027

 
(5,353
)
Other - net
 
637

 
387

 
244

 
144

 
223

 
59

Total income taxes
 

$91,787

 

$138,696

 

$49,757

 

$2,277

 

$30,108

 

$68,853

Effective Income Tax Rate
 
36.2
%
 
25.1
%
 
37.7
%
 
15.3
%
 
34.2
%
 
37.7
%


(a)
See “Income Tax Audits - 2008-2009 IRS Audit” below for discussion of the most significant items for Entergy Louisiana and System Energy.

Significant components of accumulated deferred income taxes and taxes accrued for Entergy Corporation and Subsidiaries as of December 31, 2015 and 2014 are as follows:
 
 
2015
 
2014
 
(In Thousands)
Deferred tax liabilities:
 
 
 
Plant basis differences - net

($6,804,225
)
 

($8,128,096
)
Regulatory assets
(646,392
)
 
(922,161
)
Nuclear decommissioning trusts
(1,254,463
)
 
(1,248,737
)
Pension, net funding
(365,111
)
 
(324,881
)
Combined unitary state taxes
(45,078
)
 
(162,340
)
Power purchase agreements

 
(110,889
)
Other
(315,844
)
 
(500,424
)
Total
(9,431,113
)
 
(11,397,528
)
Deferred tax assets:
 

 
 

Nuclear decommissioning liabilities
828,983

 
874,493

Regulatory liabilities
284,432

 
458,230

Pension and other post-employment benefits
525,524

 
586,455

Sale and leaseback
139,720

 
153,308

Compensation
69,432

 
74,692

Accumulated deferred investment tax credit
95,248

 
100,442

Provision for allowances and contingencies
188,282

 
160,551

Power purchase agreements
38,401

 

Net operating loss carryforwards
360,188

 
457,758

Capital losses and miscellaneous tax credits
11,075

 
12,146

Valuation allowance
(91,532
)
 
(27,387
)
Other
68,204

 
58,334

Total
2,517,957

 
2,909,022

Non-current accrued taxes (including unrecognized tax benefits)
(1,338,806
)
 
(606,560
)
Accumulated deferred income taxes and taxes accrued

($8,251,962
)
 

($9,095,066
)


Entergy’s estimated tax attributes carryovers and their expiration dates as of December 31, 2015 are as follows:
Carryover Description
 
Carryover Amount
 
Year(s) of expiration
 
 
 
 
 
Federal net operating losses
 
$3.6 billion
 
2023-2035
State net operating losses
 
$5.2 billion
 
2016-2035
Miscellaneous federal and state credits
 
$77.9 million
 
2016-2035


As a result of the accounting for uncertain tax positions, the amount of the deferred tax assets reflected in the financial statements is less than the amount of the tax effect of the federal and state net operating loss carryovers, tax credit carryovers, and other tax attributes reflected on income tax returns. Because it is more likely than not that the benefit from certain state net operating loss carryovers will not be utilized, valuation allowances of $46 million as of December 31, 2015 and $21 million as of December 31, 2014 have been provided on the deferred tax assets relating to these state net operating loss carryovers. Additionally, valuation allowances totaling $45.5 million as of December 31, 2015 have been provided on deferred tax assets related to state jurisdictions in which Entergy does not currently expect to be able to utilize separate company tax return losses, preventing realization of such deferred tax assets.
Significant components of accumulated deferred income taxes and taxes accrued for the Registrant Subsidiaries as of December 31, 2015 and 2014 are as follows:
2015
Entergy
Arkansas
 
Entergy
Louisiana
 
Entergy
Mississippi
 
Entergy
New Orleans
 
Entergy
Texas
 
System
Energy
 
(In Thousands)
Deferred tax liabilities:
 
 
 
 
 
 
 
 
 
 
 
Plant basis differences - net

($1,710,444
)
 

($2,041,968
)
 

($781,427
)
 

($167,294
)
 

($778,270
)
 

($611,745
)
Regulatory assets
(108,422
)
 
(254,316
)
 
(24,918
)
 
(39,451
)
 
(172,117
)
 
(46,990
)
Nuclear decommissioning trusts
(121,326
)
 
(99,980
)
 

 

 

 
(68,370
)
Pension, net funding
(107,073
)
 
(109,709
)
 
(30,901
)
 
(14,459
)
 
(28,001
)
 
(25,791
)
Deferred fuel
(7,647
)
 
(2,513
)
 
(684
)
 
(175
)
 
2,050

 
(18
)
Other
(38,683
)
 
(86,275
)
 
(5,625
)
 
(12,253
)
 
(10,109
)
 
(22,478
)
Total
(2,093,595
)
 
(2,594,761
)
 
(843,555
)
 
(233,632
)
 
(986,447
)
 
(775,392
)
Deferred tax assets:
 

 
 

 
 

 
 

 
 

 
 

Regulatory liabilities
18,369

 
215,154

 
7,787

 
20,888

 
7,307

 
14,927

Nuclear decommissioning liabilities
109,962

 
49,333

 

 

 

 
39,420

Pension and other post-employment benefits
(20,420
)
 
149,680

 
(6,628
)
 
(8,939
)
 
(16,703
)
 
(1,037
)
Sale and leaseback

 
37,236

 

 

 

 
102,484

Accumulated deferred investment tax credit
14,320

 
56,635

 
1,777

 
290

 
4,842

 
17,385

Provision for allowances and contingencies
1,024

 
123,007

 
18,735

 
33,843

 
7,266

 
134

Power purchase agreements
(1,279
)
 
13,840

 
1,901

 
13

 
575

 

Unbilled/deferred revenues
9,815

 
(32,365
)
 
7,154

 
2,126

 
10,851

 

Compensation
1,842

 
4,182

 
601

 
880

 
4,496

 

Net operating loss carryforwards

 
90,241

 

 

 

 

Other
128

 
21,982

 
1,995

 
316

 
1,672

 

Total
133,761

 
728,925

 
33,322

 
49,417

 
20,306

 
173,313

Non-current accrued taxes (including unrecognized tax benefits)
(22,978
)
 
(641,120
)
 
(402
)
 
(29,846
)
 
(40,693
)
 
(416,996
)
Accumulated deferred income taxes and taxes accrued

($1,982,812
)
 

($2,506,956
)
 

($810,635
)
 

($214,061
)
 

($1,006,834
)
 

($1,019,075
)
2014
 
Entergy
Arkansas
 
Entergy
Louisiana
 
Entergy
Mississippi
 
Entergy
New Orleans
 
Entergy
Texas
 
System
Energy
 
 
(In Thousands)
Deferred tax liabilities:
 
 
 
 
 
 
 
 
 
 
 
 
Plant basis differences - net
 

($1,657,503
)
 

($2,748,852
)
 

($753,576
)
 

($186,153
)
 

($771,135
)
 

($668,779
)
Regulatory assets
 
(198,662
)
 
(380,719
)
 
(30,114
)
 

 
(202,402
)
 
(110,087
)
Nuclear decommissioning trusts
 
(130,524
)
 
(106,162
)
 

 

 

 
(74,063
)
Pension, net funding
 
(93,355
)
 
(99,593
)
 
(27,861
)
 
(13,285
)
 
(25,616
)
 
(23,440
)
Deferred fuel
 
(82,050
)
 
(3,534
)
 
(5,303
)
 
(407
)
 
2,045

 
(120
)
Power purchase agreements
 
(17,073
)
 
(67,083
)
 
2,129

 
13

 
847

 

Other
 
(33,827
)
 
(84,282
)
 
(11,423
)
 
(11,500
)
 
(22,546
)
 
(19,802
)
Total
 
(2,212,994
)
 
(3,490,225
)
 
(826,148
)
 
(211,332
)
 
(1,018,807
)
 
(896,291
)
Deferred tax assets:
 
 

 
 

 
 

 
 

 
 

 
 

Regulatory liabilities
 
145,466

 
181,601

 
7,214

 
29,580

 
4,079

 
90,290

Nuclear decommissioning liabilities
 
(43,134
)
 
146,138

 

 

 

 
(62,571
)
Pension and other post-employment benefits
 
(17,534
)
 
158,661

 
(7,288
)
 
(7,504
)
 
(15,053
)
 
(1,413
)
Sale and leaseback
 

 
45,136

 

 

 

 
108,172

Accumulated deferred investment tax credit
 
14,791

 
58,863

 
2,436

 
332

 
5,158

 
18,862

Provision for allowances and contingencies
 
(7,149
)
 
125,805

 
19,590

 
10,986

 
8,017

 
133

Unbilled/deferred revenues
 
12,322

 
(25,016
)
 
12,956

 
3,395

 
11,573

 

Compensation
 
2,085

 
158

 
(846
)
 
475

 
4,155

 

Net operating loss carryforwards
 
105,063

 
241,803

 

 

 

 

Capital losses and miscellaneous tax credits
 

 

 
3,504

 

 

 

Other
 
258

 
15,508

 
5,887

 
2,891

 
3,850

 
2,000

Total
 
212,168

 
948,657

 
43,453

 
40,155

 
21,779

 
155,473

Non-current accrued taxes (including unrecognized tax benefits)
 
9,367

 
(412,508
)
 
(12,481
)
 
(19,502
)
 
(48,921
)
 
(81,528
)
Accumulated deferred income taxes and taxes accrued
 

($1,991,459
)
 

($2,954,076
)
 

($795,176
)
 

($190,679
)
 

($1,045,949
)
 

($822,346
)


The Registrant Subsidiaries’ estimated tax attributes carryovers and their expiration dates as of December 31, 2015 are as follows:
 
 
 
Entergy
Arkansas
 
 
Entergy
Louisiana
 
 
Entergy
Mississippi
 
Entergy
New Orleans
 
 
Entergy
Texas
 
 
System
Energy
 
 
 
 
 
 
 
 
 
 
 
 
 
Federal net operating losses
 
$7 million
 
$2.4 billion
 
 
 
 
$242 million
Year(s) of expiration
 
2030-2035
 
2035
 
N/A
 
N/A
 
N/A
 
2030-2035
 
 
 
 
 
 
 
 
 
 
 
 
 
State net operating losses
 
 
$2.5 billion
 
 
$6 million
 
 
$833 million
Year(s) of expiration
 
N/A
 
2035
 
N/A
 
2032
 
N/A
 
2035
 
 
 
 
 
 
 
 
 
 
 
 
 
Misc. federal credits
 
$1 million
 
 
$1 million
 
 
 
$1 million
Year(s) of expiration
 
2029-2033
 
N/A
 
2029-2034
 
N/A
 
N/A
 
2029-2033
 
 
 
 
 
 
 
 
 
 
 
 
 
State credits
 
 
 
 
 
$3.3 million
 
$6 million
Year(s) of expiration
 
N/A
 
N/A
 
N/A
 
N/A
 
2026
 
2017-2020


As a result of the accounting for uncertain tax positions, the amount of the deferred tax assets reflected in the financial statements is less than the amount of the tax effect of the federal and state net operating loss carryovers and tax credit carryovers.

Unrecognized tax benefits

Accounting standards establish a “more-likely-than-not” recognition threshold that must be met before a tax benefit can be recognized in the financial statements.  If a tax deduction is taken on a tax return, but does not meet the more-likely-than-not recognition threshold, an increase in income tax liability, above what is payable on the tax return, is required to be recorded.  A reconciliation of Entergy’s beginning and ending amount of unrecognized tax benefits is as follows:
 
2015
 
2014
 
2013
 
(In Thousands)
Gross balance at January 1

$4,736,785

 

$4,593,224

 

$4,170,403

Additions based on tax positions related to the current year
1,850,705

 
348,543

 
162,338

Additions for tax positions of prior years
59,815

 
11,637

 
410,108

Reductions for tax positions of prior years (a)
(3,966,535
)
 
(213,401
)
 
(103,360
)
Settlements
(68,227
)
 

 
(43,620
)
Lapse of statute of limitations
(958
)
 
(3,218
)
 
(2,645
)
Gross balance at December 31
2,611,585

 
4,736,785

 
4,593,224

Offsets to gross unrecognized tax benefits:
 

 
 

 
 

Credit and loss carryovers
(1,264,483
)
 
(4,295,643
)
 
(4,400,498
)
Unrecognized tax benefits net of unused tax attributes and payments (b)

$1,347,102

 

$441,142

 

$192,726



(a)
The primary reduction is related to the nuclear decommissioning costs treatment discussed in “Income Tax Audits - 2008-2009 IRS Audit” below.
(b)
Potential tax liability above what is payable on tax returns

The balances of unrecognized tax benefits include $955 million, $516 million, and $176 million as of December 31, 2015, 2014, and 2013, respectively, which, if recognized, would lower the effective income tax rates.  Because of the effect of deferred tax accounting, the remaining balances of unrecognized tax benefits of $1.657 billion, $4.221 billion, and $4.417 billion as of December 31, 2015, 2014, and 2013, respectively, if disallowed, would not affect the annual effective income tax rate but would accelerate the payment of cash to the taxing authority to an earlier period.

Entergy accrues interest expense, if any, related to unrecognized tax benefits in income tax expense.  Entergy’s December 31, 2015, 2014, and 2013 accrued balance for the possible payment of interest is approximately $27 million, $127 million, and $96.4 million, respectively.

A reconciliation of the Registrant Subsidiaries’ beginning and ending amount of unrecognized tax benefits for 2015, 2014, and 2013 is as follows:
2015
 
Entergy
Arkansas
 
Entergy
Louisiana
 
Entergy
Mississippi
 
Entergy
New Orleans
 
Entergy
Texas
 
System
Energy
 
 
(In Thousands)
Gross balance at January 1, 2015
 

$362,912

 

$1,205,929

 

$20,144

 

$53,763

 

$17,264

 

$258,242

Additions based on tax positions related to the current year (a)
 
2,196

 
1,367,058

 
566

 
472

 
657

 
472,304

Additions for tax positions of prior years
 
1,057

 
7,992

 
8,140

 
48

 
2,914

 
913

Reductions for tax positions of prior years
 
(340,720
)
 
(859,430
)
 

 
(386
)
 
(3,981
)
 
(253,141
)
Settlements
 

 
(30,888
)
 
(9,368
)
 

 
(3,392
)
 

Gross balance at December 31, 2015
 
25,445

 
1,690,661

 
19,482

 
53,897

 
13,462

 
478,318

Offsets to gross unrecognized tax benefits:
 
 

 
 

 
 

 
 

 
 

 
 

Loss carryovers
 
(3,613
)
 
(893,764
)
 
(1,016
)
 
(506
)
 
(276
)
 
(133,611
)
Unrecognized tax benefits net of unused tax attributes and payments
 

$21,832

 

$796,897

 

$18,466

 

$53,391

 

$13,186

 

$344,707



(a)
The primary addition for Entergy Louisiana and System Energy is related to the nuclear decommissioning costs treatment discussed in “Other Tax Matters” below.

2014
 
Entergy
Arkansas
 
Entergy
Louisiana
 
Entergy
Mississippi
 
Entergy
New Orleans
 
Entergy
Texas
 
System
Energy
 
 
(In Thousands)
Gross balance at January 1, 2014
 

$347,713

 

$1,076,680

 

$16,186

 

$51,679

 

$13,017

 

$265,185

Additions based on tax positions related to the current year
 
14,511

 
151,249

 
3,928

 
2,235

 
4,225

 
2,744

Additions for tax positions of prior years
 
1,767

 
6,924

 
319

 
37

 
303

 
566

Reductions for tax positions of prior years
 
(1,079
)
 
(28,924
)
 
(289
)
 
(188
)
 
(267
)
 
(10,253
)
Settlements
 

 

 

 

 
(14
)
 

Gross balance at December 31, 2014
 
362,912

 
1,205,929

 
20,144

 
53,763

 
17,264

 
258,242

Offsets to gross unrecognized tax benefits:
 
 

 
 

 
 

 
 

 
 

 
 

Loss carryovers
 
(361,043
)
 
(739,988
)
 
(6,992
)
 
(20,735
)
 
(241
)
 
(163,124
)
Unrecognized tax benefits net of unused tax attributes and payments
 

$1,869

 

$465,941

 

$13,152

 

$33,028

 

$17,023

 

$95,118


2013
 
Entergy
Arkansas
 
Entergy
Louisiana
 
Entergy
Mississippi
 
Entergy
New Orleans
 
Entergy
Texas
 
System
Energy
 
 
(In Thousands)
Gross balance at January 1, 2013
 

$344,669

 

$1,002,394

 

$16,841

 

$52,018

 

$13,954

 

$260,346

Additions based on tax positions related to the current year
 
6,427

 
17,887

 
957

 
583

 
2,170

 
4,170

Additions for tax positions of prior years
 
1,228

 
125,214

 
401

 
3,506

 
587

 
8,391

Reductions for tax positions of prior years
 
(3,943
)
 
(53,473
)
 
(1,941
)
 
(962
)
 
(4,186
)
 
(967
)
Settlements
 
(668
)
 
(15,342
)
 
(72
)
 
(3,466
)
 
492

 
(6,755
)
Gross balance at December 31, 2013
 
347,713

 
1,076,680

 
16,186

 
51,679

 
13,017

 
265,185

Offsets to gross unrecognized tax benefits:
 
 

 
 

 
 

 
 

 
 

 
 

Loss carryovers
 
(345,674
)
 
(747,756
)
 
(16,186
)
 
(22,078
)
 
(266
)
 
(225,286
)
Unrecognized tax benefits net of unused tax attributes and payments
 

$2,039

 

$328,924

 

$—

 

$29,601

 

$12,751

 

$39,899



The Registrant Subsidiaries’ balances of unrecognized tax benefits included amounts which, if recognized, would have reduced income tax expense as follows:
 
December 31,
 
2015
 
2014
 
2013
 
(In Millions)
Entergy Arkansas

$4.5

 

$2.6

 

$0.6

Entergy Louisiana

$692.7

 

$267.3

 

$131.9

Entergy Mississippi

$8.1

 

$3.9

 

$3.9

Entergy New Orleans

$50.7

 

$50.7

 

$—

Entergy Texas

$5.2

 

$10.5

 

$10.1

System Energy

$0.7

 

$3.7

 

$3.3



The Registrant Subsidiaries accrue interest and penalties related to unrecognized tax benefits in income tax expense.  Penalties have not been accrued.  Accrued balances for the possible payment of interest are as follows:
 
December 31,
 
2015
 
2014
 
2013
 
(In Millions)
Entergy Arkansas

$1.3

 

$17.0

 

$15.2

Entergy Louisiana

$9.3

 

$22.2

 

$18.0

Entergy Mississippi

$0.4

 

$2.8

 

$2.1

Entergy New Orleans

$1.8

 

$1.3

 

$0.9

Entergy Texas

$1.2

 

$1.0

 

$0.8

System Energy

$0.7

 

$23.8

 

$19.0



Income Tax Audits

Entergy and its subsidiaries file U.S. federal and various state and foreign income tax returns.  IRS examinations are complete for years before 2010. All state taxing authorities’ examinations are completed for years before 2009.

2006-2007 IRS Audit

In the first quarter 2015, the IRS finalized tax and interest computations from the 2006-2007 audit that resulted in a reversal of Entergy’s provision for uncertain tax positions related to accrued interest of approximately $20 million, including decreases of approximately $4 million for Entergy Arkansas, $11 million for Entergy Louisiana, and $1 million for System Energy.

2008-2009 IRS Audit

In the fourth quarter 2009, Entergy filed Applications for Change in Accounting Method (the “2009 CAM”) for tax purposes with the IRS for certain costs under Section 263A of the Internal Revenue Code.  In the Applications, Entergy proposed to treat the nuclear decommissioning liability associated with the operation of its nuclear power plants as a production cost properly includable in cost of goods sold.  The effect of the 2009 CAM was a $5.7 billion reduction in 2009 taxable income.  The 2009 CAM was adjusted to $9.3 billion in 2012.

In the fourth quarter 2012 the IRS disallowed the reduction to 2009 taxable income related to the 2009 CAM.  In the third quarter 2013, the Internal Revenue Service issued its RAR for the tax years 2008-2009. As a result of the issuance of this RAR, Entergy and the IRS resolved all of the 2008-2009 issues described above except for the 2009 CAM. Entergy disagreed with the IRS’s disallowance of the 2009 CAM and filed a protest with the IRS Appeals Division in October 2013.

In August 2015, Entergy and the IRS agreed on the treatment of the 2009 position regarding nuclear decommissioning liabilities from the 2008-2009 audit. The agreement provides that Entergy is entitled to deduct approximately $118 million of the $9.3 billion claimed in 2009. The agreement effectively settled all matters pertaining to the 2009 tax year and increased Entergy’s 2009 federal income tax liability by $2.4 million.

2010-2011 IRS Audit

The IRS examination of the 2010 and 2011 years is ongoing and the audit field work is expected to be completed by the end of the first quarter of 2016. The IRS has not issued any significant notices of proposed adjustments other than for the decommissioning liability position discussed above. The Revenue Agent’s Report is expected to be received shortly after the completion of field work.

Other Tax Matters

Entergy regularly negotiates with the IRS to achieve settlements.  The resolution of audit issues could result in significant changes to the amounts of unrecognized tax benefits in the next twelve months.

In September 2013 the U.S. Treasury Department and the IRS issued final regulations that provide guidance on the deductibility and capitalization of costs incurred associated with tangible property. Entergy and the Registrant Subsidiaries filed with the IRS an automatic application for change in accounting method which is in compliance with the final regulations and the safe harbor provisions of the relevant IRS Revenue Procedures. Entergy estimates that the effect of this accounting method change will result in a net increase to Entergy’s taxable income of approximately $585 million, which will be recognized generally over a four year period beginning with the tax year ended 2014. The adoption of the final regulations and safe harbor method results in approximate changes in the Registrant Subsidiaries taxable income as follows: an increase of $177 million for Entergy Arkansas, an increase of $78 million for Entergy Louisiana, an increase of $26 million for Entergy Mississippi, an increase of $183 million for Entergy Texas, a decrease of $2 million for Entergy New Orleans, and an increase of $22 million for System Energy.

In October 2015 two of Entergy’s Louisiana utilities, Entergy Gulf States Louisiana and Entergy Louisiana, combined their businesses into a legal entity which is identified as Entergy Louisiana herein. Entergy Louisiana maintained a carryover tax basis in the assets received. Additionally, the tax consequences provided for an increase in tax basis as well. To the extent that this increase in tax basis will provide additional tax depreciation, Entergy recorded a deferred tax asset and current tax expense resulting in a net increase in tax basis of approximately $334 million and Entergy Louisiana obtained a corresponding deferred tax asset. Consistent with the terms of an agreement with the LPSC, electric customers of Entergy Louisiana will realize customer credits associated with the business combination. Accordingly, in October 2015, Entergy recorded a regulatory liability of $107 million ($66 million net-of-tax) which partially offsets the effect of the aforementioned deferred tax asset. The deferred tax asset and the regulatory liability, net-of-tax, increased Entergy Louisiana’s member’s equity by $268 million. See Note 2 to the financial statements for further discussion of the business combination.

In the fourth quarter 2015, System Energy and Entergy Louisiana adopted a new method of accounting for income tax purposes in which the companies’ nuclear decommissioning costs will be treated as production costs of electricity includable in cost of goods sold. The new method results in a reduction of taxable income of $1.2 billion for System Energy and $2.2 billion for Entergy Louisiana.

The Protecting Americans from Tax Hikes Act of 2015 was enacted in December 2015. The most significant provisions affecting Entergy and the Registrant Subsidiaries were a five-year extension of bonus depreciation and permanent extension of the research and experimentation tax credit. The effect of the bonus depreciation extension on 2015 increased Entergy’s tax net operating loss.
Entergy Mississippi [Member]  
Income Taxes
INCOME TAXES (Entergy Corporation, Entergy Arkansas, Entergy Louisiana, Entergy Mississippi, Entergy New Orleans, Entergy Texas, and System Energy)

Income taxes for 2015, 2014, and 2013 for Entergy Corporation and Subsidiaries consist of the following:
 
2015
 
2014
 
2013
 
(In Thousands)
Current:
 
 
 
 
 
Federal

$77,166

 

$90,061

 

$88,291

Foreign
97

 
90

 
101

State
157,829

 
(12,637
)
 
20,584

Total
235,092

 
77,514

 
108,976

Deferred and non-current - net
(864,799
)
 
528,326

 
126,935

Investment tax credit adjustments - net
(13,220
)
 
(16,243
)
 
(9,930
)
Income taxes

($642,927
)
 

$589,597

 

$225,981



Income taxes for 2015, 2014, and 2013 for Entergy’s Registrant Subsidiaries consist of the following:
2015
 
Entergy
Arkansas
 
Entergy
Louisiana
 
Entergy
Mississippi
 
Entergy
New Orleans
 
Entergy
Texas
 
System
Energy
 
 
(In Thousands)
Current:
 
 
 
 
 
 
 
 
 
 
 
 
Federal
 

$66,966

 

$101,382

 

$25,628

 

($9,346
)
 

$53,313

 

($63,302
)
State
 
6,265

 
35,406

 
6,832

 
1,784

 
2,450

 
26,755

Total
 
73,231

 
136,788

 
32,460

 
(7,562
)
 
55,763

 
(36,547
)
Deferred and non-current - net
 
(31,463
)
 
47,220

 
31,149

 
32,890

 
(17,599
)
 
93,491

Investment tax credit adjustments - net
 
(1,227
)
 
(5,337
)
 
(1,737
)
 
(138
)
 
(914
)
 
(3,867
)
Income taxes
 

$40,541

 

$178,671

 

$61,872

 

$25,190

 

$37,250

 

$53,077


2014
 
Entergy
Arkansas
 
Entergy
Louisiana
 
Entergy
Mississippi
 
Entergy
New Orleans
 
Entergy
Texas
 
System
Energy
 
 
(In Thousands)
Current:
 
 
 
 
 
 
 
 
 
 
 
 
Federal
 

($34,258
)
 

($44,909
)
 

$8,103

 

($1,428
)
 

$48,610

 

$19,908

State
 
(678
)
 
(1,191
)
 
7,474

 
510

 
4,877

 
15,379

Total
 
(34,936
)
 
(46,100
)
 
15,577

 
(918
)
 
53,487

 
35,287

Deferred and non-current - net
 
119,841

 
236,794

 
42,305

 
14,592

 
(2,418
)
 
53,501

Investment tax credit adjustments - net
 
(1,276
)
 
(5,642
)
 
(2,172
)
 
(224
)
 
(1,425
)
 
(5,478
)
Income taxes
 

$83,629

 

$185,052

 

$55,710

 

$13,450

 

$49,644

 

$83,310


2013
 
Entergy
Arkansas
 
Entergy
Louisiana
 
Entergy
Mississippi
 
Entergy
New Orleans
 
Entergy
Texas
 
System
Energy
 
 
(In Thousands)
Current:
 
 
 
 
 
 
 
 
 
 
 
 
Federal
 

($13,574
)
 

($18,797
)
 

$2,498

 

$14,823

 

$37,199

 

($6,199
)
State
 
6,122

 
(15,631
)
 
4,849

 
(1,267
)
 
(843
)
 
15,845

Total
 
(7,452
)
 
(34,428
)
 
7,347

 
13,556

 
36,356

 
9,646

Deferred and non-current - net
 
101,253

 
179,036

 
41,150

 
(11,033
)
 
(4,639
)
 
60,614

Investment tax credit adjustments - net
 
(2,014
)
 
(5,912
)
 
1,260

 
(246
)
 
(1,609
)
 
(1,407
)
Income taxes
 

$91,787

 

$138,696

 

$49,757

 

$2,277

 

$30,108

 

$68,853



Total income taxes for Entergy Corporation and Subsidiaries differ from the amounts computed by applying the statutory income tax rate to income before income taxes.  The reasons for the differences for the years 2015, 2014, and 2013 are:
 
2015
 
2014
 
2013
 
(In Thousands)
Net income (loss) attributable to Entergy Corporation

($176,562
)
 

$940,721

 

$711,902

Preferred dividend requirements of subsidiaries
19,828

 
19,536

 
18,670

Consolidated net income (loss)
(156,734
)
 
960,257

 
730,572

Income taxes
(642,927
)
 
589,597

 
225,981

Income (loss) before income taxes

($799,661
)
 

$1,549,854

 

$956,553

Computed at statutory rate (35%)

($279,881
)
 

$542,449

 

$334,794

Increases (reductions) in tax resulting from:
 

 
 

 
 

State income taxes net of federal income tax effect
29,944

 
44,708

 
13,599

Regulatory differences - utility plant items
32,089

 
39,321

 
32,324

Equity component of AFUDC
(18,191
)
 
(21,108
)
 
(22,356
)
Amortization of investment tax credits
(11,136
)
 
(12,211
)
 
(13,535
)
Flow-through / permanent differences
(7,872
)
 
(18,003
)
 
(301
)
Net-of-tax regulatory liability

 

 
(2,899
)
New York tax law change (a)

 
(21,500
)
 

Louisiana business combination
(333,655
)
 

 

Termination of business reorganization

 

 
(27,192
)
Provision for uncertain tax positions (b)
(56,683
)
 
32,573

 
(59,249
)
Valuation allowance

 

 
(31,573
)
Other - net
2,458

 
3,368

 
2,369

Total income taxes as reported

($642,927
)
 

$589,597

 

$225,981

Effective Income Tax Rate
80.4
%
 
38.0
%
 
23.6
%


(a)
In March 2014, New York enacted legislation that substantially modifies various aspects of New York tax law. The most significant effect of the legislation for Entergy is the adoption of full water’s-edge unitary combined reporting, meaning that all of Entergy’s domestic entities will be included in New York’s combined filing group. The effect of the tax law change resulted in a deferred state income tax reduction of approximately $21.5 million as shown in the table above.
(b)
See “Income Tax Audits - 2008-2009 IRS Audit” below for discussion of the most significant items for 2015 and 2013.

Total income taxes for the Registrant Subsidiaries differ from the amounts computed by applying the statutory income tax rate to income before taxes.  The reasons for the differences for the years 2015, 2014, and 2013 are:
2015
 
Entergy
Arkansas
 
Entergy
Louisiana
 
Entergy
Mississippi
 
Entergy
New Orleans
 
Entergy
Texas
 
System
Energy
 
 
(In Thousands)
Net income
 

$74,272

 

$446,639

 

$92,708

 

$44,925

 

$69,625

 

$111,318

Income taxes
 
40,541

 
178,671

 
61,872

 
25,190

 
37,250

 
53,077

Pretax income
 

$114,813

 

$625,310

 

$154,580

 

$70,115

 

$106,875

 

$164,395

Computed at statutory rate (35%)
 

$40,185

 

$218,859

 

$54,103

 

$24,540

 

$37,406

 

$57,538

Increases (reductions) in tax resulting from:
 
 
 
 

 
 

 
 

 
 

 
 

State income taxes net of federal income tax effect
 
6,643

 
23,650

 
5,219

 
2,887

 
1,621

 
6,403

Regulatory differences - utility plant items
 
7,299

 
3,013

 
2,383

 
2,201

 
3,703

 
12,167

Equity component of AFUDC
 
(4,979
)
 
(5,420
)
 
(1,083
)
 
(451
)
 
(1,987
)
 
(2,973
)
Amortization of investment tax credits
 
(1,201
)
 
(5,252
)
 
(160
)
 
(111
)
 
(900
)
 
(3,476
)
Flow-through / permanent differences
 
(4,062
)
 
2,460

 
431

 
(4,539
)
 
530

 
618

Non-taxable dividend income
 

 
(44,658
)
 

 

 

 

Provision for uncertain tax positions (a)
 
(3,978
)
 
(15,377
)
 
756

 
525

 
(3,365
)
 
(17,313
)
Other - net
 
634

 
1,396

 
223

 
138

 
242

 
113

Total income taxes
 

$40,541

 

$178,671

 

$61,872

 

$25,190

 

$37,250

 

$53,077

Effective Income Tax Rate
 
35.3
%
 
28.6
%
 
40.0
%
 
35.9
%
 
34.9
%
 
32.3
%


(a)
See “Income Tax Audits - 2008-2009 IRS Audit” below for discussion of the most significant items for Entergy Louisiana and System Energy.

2014
 
Entergy
Arkansas
 
Entergy
Louisiana
 
Entergy
Mississippi
 
Entergy
New Orleans
 
Entergy
Texas
 
System
Energy
 
 
(In Thousands)
Net income
 

$121,392

 

$446,022

 

$74,821

 

$31,030

 

$74,804

 

$96,334

Income taxes
 
83,629

 
185,052

 
55,710

 
13,450

 
49,644

 
83,310

Pretax income
 

$205,021

 

$631,074

 

$130,531

 

$44,480

 

$124,448

 

$179,644

Computed at statutory rate (35%)
 

$71,757

 

$220,876

 

$45,686

 

$15,568

 

$43,557

 

$62,875

Increases (reductions) in tax resulting from:
 
 

 
 

 
 

 
 

 
 

 
 

State income taxes net of federal income tax effect
 
9,591

 
11,666

 
5,180

 
1,562

 
3,221

 
6,877

Regulatory differences - utility plant items
 
8,653

 
7,487

 
4,448

 
777

 
4,165

 
13,791

Equity component of AFUDC
 
(2,533
)
 
(14,612
)
 
(833
)
 
(320
)
 
(1,035
)
 
(1,774
)
Amortization of investment tax credits
 
(1,251
)
 
(5,594
)
 
(260
)
 
(218
)
 
(1,412
)
 
(3,476
)
Flow-through / permanent differences
 
(5,082
)
 
(225
)
 
555

 
(4,458
)
 
393

 
(327
)
Non-taxable dividend income
 

 
(41,255
)
 

 

 

 

Provision for uncertain tax positions
 
1,881

 
5,336

 
718

 
405

 
522

 
5,235

Other - net
 
613

 
1,373

 
216

 
134

 
233

 
109

Total income taxes
 

$83,629

 

$185,052

 

$55,710

 

$13,450

 

$49,644

 

$83,310

Effective Income Tax Rate
 
40.8
%
 
29.3
%
 
42.7
%
 
30.2
%
 
39.9
%
 
46.4
%


2013
 
Entergy
Arkansas
 
Entergy
Louisiana
 
Entergy
Mississippi
 
Entergy
New Orleans
 
Entergy
Texas
 
System
Energy
 
 
(In Thousands)
Net income
 

$161,948

 

$414,126

 

$82,159

 

$12,608

 

$57,881

 

$113,664

Income taxes
 
91,787

 
138,696

 
49,757

 
2,277

 
30,108

 
68,853

Pretax income
 

$253,735

 

$552,822

 

$131,916

 

$14,885

 

$87,989

 

$182,517

Computed at statutory rate (35%)
 

$88,807

 

$193,488

 

$46,171

 

$5,210

 

$30,796

 

$63,881

Increases (reductions) in tax resulting from:
 
 

 
 

 
 

 
 

 
 

 
 

State income taxes net of federal income tax effect
 
10,954

 
19,084

 
4,564

 
1,116

 
(897
)
 
5,900

Regulatory differences - utility plant items
 
7,938

 
7,005

 
2,603

 
453

 
3,256

 
11,070

Equity component of AFUDC
 
(3,820
)
 
(13,100
)
 
(764
)
 
(322
)
 
(1,626
)
 
(2,724
)
Amortization of investment tax credits
 
(1,989
)
 
(5,864
)
 
(260
)
 
(216
)
 
(1,596
)
 
(3,476
)
Flow-through / permanent differences
 
2,540

 
3,646

 
1,702

 
(4,402
)
 
2,467

 
(491
)
Net-of-tax regulatory liability
 

 
(2,899
)
 

 

 

 

Termination of business organization
 
(6,753
)
 
(7,453
)
 
(4,177
)
 
(501
)
 
(3,542
)
 
(13
)
Non-taxable dividend income
 

 
(36,953
)
 

 

 

 

Provision for uncertain tax positions (a)
 
(6,527
)
 
(18,645
)
 
(326
)
 
795

 
1,027

 
(5,353
)
Other - net
 
637

 
387

 
244

 
144

 
223

 
59

Total income taxes
 

$91,787

 

$138,696

 

$49,757

 

$2,277

 

$30,108

 

$68,853

Effective Income Tax Rate
 
36.2
%
 
25.1
%
 
37.7
%
 
15.3
%
 
34.2
%
 
37.7
%


(a)
See “Income Tax Audits - 2008-2009 IRS Audit” below for discussion of the most significant items for Entergy Louisiana and System Energy.

Significant components of accumulated deferred income taxes and taxes accrued for Entergy Corporation and Subsidiaries as of December 31, 2015 and 2014 are as follows:
 
 
2015
 
2014
 
(In Thousands)
Deferred tax liabilities:
 
 
 
Plant basis differences - net

($6,804,225
)
 

($8,128,096
)
Regulatory assets
(646,392
)
 
(922,161
)
Nuclear decommissioning trusts
(1,254,463
)
 
(1,248,737
)
Pension, net funding
(365,111
)
 
(324,881
)
Combined unitary state taxes
(45,078
)
 
(162,340
)
Power purchase agreements

 
(110,889
)
Other
(315,844
)
 
(500,424
)
Total
(9,431,113
)
 
(11,397,528
)
Deferred tax assets:
 

 
 

Nuclear decommissioning liabilities
828,983

 
874,493

Regulatory liabilities
284,432

 
458,230

Pension and other post-employment benefits
525,524

 
586,455

Sale and leaseback
139,720

 
153,308

Compensation
69,432

 
74,692

Accumulated deferred investment tax credit
95,248

 
100,442

Provision for allowances and contingencies
188,282

 
160,551

Power purchase agreements
38,401

 

Net operating loss carryforwards
360,188

 
457,758

Capital losses and miscellaneous tax credits
11,075

 
12,146

Valuation allowance
(91,532
)
 
(27,387
)
Other
68,204

 
58,334

Total
2,517,957

 
2,909,022

Non-current accrued taxes (including unrecognized tax benefits)
(1,338,806
)
 
(606,560
)
Accumulated deferred income taxes and taxes accrued

($8,251,962
)
 

($9,095,066
)


Entergy’s estimated tax attributes carryovers and their expiration dates as of December 31, 2015 are as follows:
Carryover Description
 
Carryover Amount
 
Year(s) of expiration
 
 
 
 
 
Federal net operating losses
 
$3.6 billion
 
2023-2035
State net operating losses
 
$5.2 billion
 
2016-2035
Miscellaneous federal and state credits
 
$77.9 million
 
2016-2035


As a result of the accounting for uncertain tax positions, the amount of the deferred tax assets reflected in the financial statements is less than the amount of the tax effect of the federal and state net operating loss carryovers, tax credit carryovers, and other tax attributes reflected on income tax returns. Because it is more likely than not that the benefit from certain state net operating loss carryovers will not be utilized, valuation allowances of $46 million as of December 31, 2015 and $21 million as of December 31, 2014 have been provided on the deferred tax assets relating to these state net operating loss carryovers. Additionally, valuation allowances totaling $45.5 million as of December 31, 2015 have been provided on deferred tax assets related to state jurisdictions in which Entergy does not currently expect to be able to utilize separate company tax return losses, preventing realization of such deferred tax assets.
Significant components of accumulated deferred income taxes and taxes accrued for the Registrant Subsidiaries as of December 31, 2015 and 2014 are as follows:
2015
Entergy
Arkansas
 
Entergy
Louisiana
 
Entergy
Mississippi
 
Entergy
New Orleans
 
Entergy
Texas
 
System
Energy
 
(In Thousands)
Deferred tax liabilities:
 
 
 
 
 
 
 
 
 
 
 
Plant basis differences - net

($1,710,444
)
 

($2,041,968
)
 

($781,427
)
 

($167,294
)
 

($778,270
)
 

($611,745
)
Regulatory assets
(108,422
)
 
(254,316
)
 
(24,918
)
 
(39,451
)
 
(172,117
)
 
(46,990
)
Nuclear decommissioning trusts
(121,326
)
 
(99,980
)
 

 

 

 
(68,370
)
Pension, net funding
(107,073
)
 
(109,709
)
 
(30,901
)
 
(14,459
)
 
(28,001
)
 
(25,791
)
Deferred fuel
(7,647
)
 
(2,513
)
 
(684
)
 
(175
)
 
2,050

 
(18
)
Other
(38,683
)
 
(86,275
)
 
(5,625
)
 
(12,253
)
 
(10,109
)
 
(22,478
)
Total
(2,093,595
)
 
(2,594,761
)
 
(843,555
)
 
(233,632
)
 
(986,447
)
 
(775,392
)
Deferred tax assets:
 

 
 

 
 

 
 

 
 

 
 

Regulatory liabilities
18,369

 
215,154

 
7,787

 
20,888

 
7,307

 
14,927

Nuclear decommissioning liabilities
109,962

 
49,333

 

 

 

 
39,420

Pension and other post-employment benefits
(20,420
)
 
149,680

 
(6,628
)
 
(8,939
)
 
(16,703
)
 
(1,037
)
Sale and leaseback

 
37,236

 

 

 

 
102,484

Accumulated deferred investment tax credit
14,320

 
56,635

 
1,777

 
290

 
4,842

 
17,385

Provision for allowances and contingencies
1,024

 
123,007

 
18,735

 
33,843

 
7,266

 
134

Power purchase agreements
(1,279
)
 
13,840

 
1,901

 
13

 
575

 

Unbilled/deferred revenues
9,815

 
(32,365
)
 
7,154

 
2,126

 
10,851

 

Compensation
1,842

 
4,182

 
601

 
880

 
4,496

 

Net operating loss carryforwards

 
90,241

 

 

 

 

Other
128

 
21,982

 
1,995

 
316

 
1,672

 

Total
133,761

 
728,925

 
33,322

 
49,417

 
20,306

 
173,313

Non-current accrued taxes (including unrecognized tax benefits)
(22,978
)
 
(641,120
)
 
(402
)
 
(29,846
)
 
(40,693
)
 
(416,996
)
Accumulated deferred income taxes and taxes accrued

($1,982,812
)
 

($2,506,956
)
 

($810,635
)
 

($214,061
)
 

($1,006,834
)
 

($1,019,075
)
2014
 
Entergy
Arkansas
 
Entergy
Louisiana
 
Entergy
Mississippi
 
Entergy
New Orleans
 
Entergy
Texas
 
System
Energy
 
 
(In Thousands)
Deferred tax liabilities:
 
 
 
 
 
 
 
 
 
 
 
 
Plant basis differences - net
 

($1,657,503
)
 

($2,748,852
)
 

($753,576
)
 

($186,153
)
 

($771,135
)
 

($668,779
)
Regulatory assets
 
(198,662
)
 
(380,719
)
 
(30,114
)
 

 
(202,402
)
 
(110,087
)
Nuclear decommissioning trusts
 
(130,524
)
 
(106,162
)
 

 

 

 
(74,063
)
Pension, net funding
 
(93,355
)
 
(99,593
)
 
(27,861
)
 
(13,285
)
 
(25,616
)
 
(23,440
)
Deferred fuel
 
(82,050
)
 
(3,534
)
 
(5,303
)
 
(407
)
 
2,045

 
(120
)
Power purchase agreements
 
(17,073
)
 
(67,083
)
 
2,129

 
13

 
847

 

Other
 
(33,827
)
 
(84,282
)
 
(11,423
)
 
(11,500
)
 
(22,546
)
 
(19,802
)
Total
 
(2,212,994
)
 
(3,490,225
)
 
(826,148
)
 
(211,332
)
 
(1,018,807
)
 
(896,291
)
Deferred tax assets:
 
 

 
 

 
 

 
 

 
 

 
 

Regulatory liabilities
 
145,466

 
181,601

 
7,214

 
29,580

 
4,079

 
90,290

Nuclear decommissioning liabilities
 
(43,134
)
 
146,138

 

 

 

 
(62,571
)
Pension and other post-employment benefits
 
(17,534
)
 
158,661

 
(7,288
)
 
(7,504
)
 
(15,053
)
 
(1,413
)
Sale and leaseback
 

 
45,136

 

 

 

 
108,172

Accumulated deferred investment tax credit
 
14,791

 
58,863

 
2,436

 
332

 
5,158

 
18,862

Provision for allowances and contingencies
 
(7,149
)
 
125,805

 
19,590

 
10,986

 
8,017

 
133

Unbilled/deferred revenues
 
12,322

 
(25,016
)
 
12,956

 
3,395

 
11,573

 

Compensation
 
2,085

 
158

 
(846
)
 
475

 
4,155

 

Net operating loss carryforwards
 
105,063

 
241,803

 

 

 

 

Capital losses and miscellaneous tax credits
 

 

 
3,504

 

 

 

Other
 
258

 
15,508

 
5,887

 
2,891

 
3,850

 
2,000

Total
 
212,168

 
948,657

 
43,453

 
40,155

 
21,779

 
155,473

Non-current accrued taxes (including unrecognized tax benefits)
 
9,367

 
(412,508
)
 
(12,481
)
 
(19,502
)
 
(48,921
)
 
(81,528
)
Accumulated deferred income taxes and taxes accrued
 

($1,991,459
)
 

($2,954,076
)
 

($795,176
)
 

($190,679
)
 

($1,045,949
)
 

($822,346
)


The Registrant Subsidiaries’ estimated tax attributes carryovers and their expiration dates as of December 31, 2015 are as follows:
 
 
 
Entergy
Arkansas
 
 
Entergy
Louisiana
 
 
Entergy
Mississippi
 
Entergy
New Orleans
 
 
Entergy
Texas
 
 
System
Energy
 
 
 
 
 
 
 
 
 
 
 
 
 
Federal net operating losses
 
$7 million
 
$2.4 billion
 
 
 
 
$242 million
Year(s) of expiration
 
2030-2035
 
2035
 
N/A
 
N/A
 
N/A
 
2030-2035
 
 
 
 
 
 
 
 
 
 
 
 
 
State net operating losses
 
 
$2.5 billion
 
 
$6 million
 
 
$833 million
Year(s) of expiration
 
N/A
 
2035
 
N/A
 
2032
 
N/A
 
2035
 
 
 
 
 
 
 
 
 
 
 
 
 
Misc. federal credits
 
$1 million
 
 
$1 million
 
 
 
$1 million
Year(s) of expiration
 
2029-2033
 
N/A
 
2029-2034
 
N/A
 
N/A
 
2029-2033
 
 
 
 
 
 
 
 
 
 
 
 
 
State credits
 
 
 
 
 
$3.3 million
 
$6 million
Year(s) of expiration
 
N/A
 
N/A
 
N/A
 
N/A
 
2026
 
2017-2020


As a result of the accounting for uncertain tax positions, the amount of the deferred tax assets reflected in the financial statements is less than the amount of the tax effect of the federal and state net operating loss carryovers and tax credit carryovers.

Unrecognized tax benefits

Accounting standards establish a “more-likely-than-not” recognition threshold that must be met before a tax benefit can be recognized in the financial statements.  If a tax deduction is taken on a tax return, but does not meet the more-likely-than-not recognition threshold, an increase in income tax liability, above what is payable on the tax return, is required to be recorded.  A reconciliation of Entergy’s beginning and ending amount of unrecognized tax benefits is as follows:
 
2015
 
2014
 
2013
 
(In Thousands)
Gross balance at January 1

$4,736,785

 

$4,593,224

 

$4,170,403

Additions based on tax positions related to the current year
1,850,705

 
348,543

 
162,338

Additions for tax positions of prior years
59,815

 
11,637

 
410,108

Reductions for tax positions of prior years (a)
(3,966,535
)
 
(213,401
)
 
(103,360
)
Settlements
(68,227
)
 

 
(43,620
)
Lapse of statute of limitations
(958
)
 
(3,218
)
 
(2,645
)
Gross balance at December 31
2,611,585

 
4,736,785

 
4,593,224

Offsets to gross unrecognized tax benefits:
 

 
 

 
 

Credit and loss carryovers
(1,264,483
)
 
(4,295,643
)
 
(4,400,498
)
Unrecognized tax benefits net of unused tax attributes and payments (b)

$1,347,102

 

$441,142

 

$192,726



(a)
The primary reduction is related to the nuclear decommissioning costs treatment discussed in “Income Tax Audits - 2008-2009 IRS Audit” below.
(b)
Potential tax liability above what is payable on tax returns

The balances of unrecognized tax benefits include $955 million, $516 million, and $176 million as of December 31, 2015, 2014, and 2013, respectively, which, if recognized, would lower the effective income tax rates.  Because of the effect of deferred tax accounting, the remaining balances of unrecognized tax benefits of $1.657 billion, $4.221 billion, and $4.417 billion as of December 31, 2015, 2014, and 2013, respectively, if disallowed, would not affect the annual effective income tax rate but would accelerate the payment of cash to the taxing authority to an earlier period.

Entergy accrues interest expense, if any, related to unrecognized tax benefits in income tax expense.  Entergy’s December 31, 2015, 2014, and 2013 accrued balance for the possible payment of interest is approximately $27 million, $127 million, and $96.4 million, respectively.

A reconciliation of the Registrant Subsidiaries’ beginning and ending amount of unrecognized tax benefits for 2015, 2014, and 2013 is as follows:
2015
 
Entergy
Arkansas
 
Entergy
Louisiana
 
Entergy
Mississippi
 
Entergy
New Orleans
 
Entergy
Texas
 
System
Energy
 
 
(In Thousands)
Gross balance at January 1, 2015
 

$362,912

 

$1,205,929

 

$20,144

 

$53,763

 

$17,264

 

$258,242

Additions based on tax positions related to the current year (a)
 
2,196

 
1,367,058

 
566

 
472

 
657

 
472,304

Additions for tax positions of prior years
 
1,057

 
7,992

 
8,140

 
48

 
2,914

 
913

Reductions for tax positions of prior years
 
(340,720
)
 
(859,430
)
 

 
(386
)
 
(3,981
)
 
(253,141
)
Settlements
 

 
(30,888
)
 
(9,368
)
 

 
(3,392
)
 

Gross balance at December 31, 2015
 
25,445

 
1,690,661

 
19,482

 
53,897

 
13,462

 
478,318

Offsets to gross unrecognized tax benefits:
 
 

 
 

 
 

 
 

 
 

 
 

Loss carryovers
 
(3,613
)
 
(893,764
)
 
(1,016
)
 
(506
)
 
(276
)
 
(133,611
)
Unrecognized tax benefits net of unused tax attributes and payments
 

$21,832

 

$796,897

 

$18,466

 

$53,391

 

$13,186

 

$344,707



(a)
The primary addition for Entergy Louisiana and System Energy is related to the nuclear decommissioning costs treatment discussed in “Other Tax Matters” below.

2014
 
Entergy
Arkansas
 
Entergy
Louisiana
 
Entergy
Mississippi
 
Entergy
New Orleans
 
Entergy
Texas
 
System
Energy
 
 
(In Thousands)
Gross balance at January 1, 2014
 

$347,713

 

$1,076,680

 

$16,186

 

$51,679

 

$13,017

 

$265,185

Additions based on tax positions related to the current year
 
14,511

 
151,249

 
3,928

 
2,235

 
4,225

 
2,744

Additions for tax positions of prior years
 
1,767

 
6,924

 
319

 
37

 
303

 
566

Reductions for tax positions of prior years
 
(1,079
)
 
(28,924
)
 
(289
)
 
(188
)
 
(267
)
 
(10,253
)
Settlements
 

 

 

 

 
(14
)
 

Gross balance at December 31, 2014
 
362,912

 
1,205,929

 
20,144

 
53,763

 
17,264

 
258,242

Offsets to gross unrecognized tax benefits:
 
 

 
 

 
 

 
 

 
 

 
 

Loss carryovers
 
(361,043
)
 
(739,988
)
 
(6,992
)
 
(20,735
)
 
(241
)
 
(163,124
)
Unrecognized tax benefits net of unused tax attributes and payments
 

$1,869

 

$465,941

 

$13,152

 

$33,028

 

$17,023

 

$95,118


2013
 
Entergy
Arkansas
 
Entergy
Louisiana
 
Entergy
Mississippi
 
Entergy
New Orleans
 
Entergy
Texas
 
System
Energy
 
 
(In Thousands)
Gross balance at January 1, 2013
 

$344,669

 

$1,002,394

 

$16,841

 

$52,018

 

$13,954

 

$260,346

Additions based on tax positions related to the current year
 
6,427

 
17,887

 
957

 
583

 
2,170

 
4,170

Additions for tax positions of prior years
 
1,228

 
125,214

 
401

 
3,506

 
587

 
8,391

Reductions for tax positions of prior years
 
(3,943
)
 
(53,473
)
 
(1,941
)
 
(962
)
 
(4,186
)
 
(967
)
Settlements
 
(668
)
 
(15,342
)
 
(72
)
 
(3,466
)
 
492

 
(6,755
)
Gross balance at December 31, 2013
 
347,713

 
1,076,680

 
16,186

 
51,679

 
13,017

 
265,185

Offsets to gross unrecognized tax benefits:
 
 

 
 

 
 

 
 

 
 

 
 

Loss carryovers
 
(345,674
)
 
(747,756
)
 
(16,186
)
 
(22,078
)
 
(266
)
 
(225,286
)
Unrecognized tax benefits net of unused tax attributes and payments
 

$2,039

 

$328,924

 

$—

 

$29,601

 

$12,751

 

$39,899



The Registrant Subsidiaries’ balances of unrecognized tax benefits included amounts which, if recognized, would have reduced income tax expense as follows:
 
December 31,
 
2015
 
2014
 
2013
 
(In Millions)
Entergy Arkansas

$4.5

 

$2.6

 

$0.6

Entergy Louisiana

$692.7

 

$267.3

 

$131.9

Entergy Mississippi

$8.1

 

$3.9

 

$3.9

Entergy New Orleans

$50.7

 

$50.7

 

$—

Entergy Texas

$5.2

 

$10.5

 

$10.1

System Energy

$0.7

 

$3.7

 

$3.3



The Registrant Subsidiaries accrue interest and penalties related to unrecognized tax benefits in income tax expense.  Penalties have not been accrued.  Accrued balances for the possible payment of interest are as follows:
 
December 31,
 
2015
 
2014
 
2013
 
(In Millions)
Entergy Arkansas

$1.3

 

$17.0

 

$15.2

Entergy Louisiana

$9.3

 

$22.2

 

$18.0

Entergy Mississippi

$0.4

 

$2.8

 

$2.1

Entergy New Orleans

$1.8

 

$1.3

 

$0.9

Entergy Texas

$1.2

 

$1.0

 

$0.8

System Energy

$0.7

 

$23.8

 

$19.0



Income Tax Audits

Entergy and its subsidiaries file U.S. federal and various state and foreign income tax returns.  IRS examinations are complete for years before 2010. All state taxing authorities’ examinations are completed for years before 2009.

2006-2007 IRS Audit

In the first quarter 2015, the IRS finalized tax and interest computations from the 2006-2007 audit that resulted in a reversal of Entergy’s provision for uncertain tax positions related to accrued interest of approximately $20 million, including decreases of approximately $4 million for Entergy Arkansas, $11 million for Entergy Louisiana, and $1 million for System Energy.

2008-2009 IRS Audit

In the fourth quarter 2009, Entergy filed Applications for Change in Accounting Method (the “2009 CAM”) for tax purposes with the IRS for certain costs under Section 263A of the Internal Revenue Code.  In the Applications, Entergy proposed to treat the nuclear decommissioning liability associated with the operation of its nuclear power plants as a production cost properly includable in cost of goods sold.  The effect of the 2009 CAM was a $5.7 billion reduction in 2009 taxable income.  The 2009 CAM was adjusted to $9.3 billion in 2012.

In the fourth quarter 2012 the IRS disallowed the reduction to 2009 taxable income related to the 2009 CAM.  In the third quarter 2013, the Internal Revenue Service issued its RAR for the tax years 2008-2009. As a result of the issuance of this RAR, Entergy and the IRS resolved all of the 2008-2009 issues described above except for the 2009 CAM. Entergy disagreed with the IRS’s disallowance of the 2009 CAM and filed a protest with the IRS Appeals Division in October 2013.

In August 2015, Entergy and the IRS agreed on the treatment of the 2009 position regarding nuclear decommissioning liabilities from the 2008-2009 audit. The agreement provides that Entergy is entitled to deduct approximately $118 million of the $9.3 billion claimed in 2009. The agreement effectively settled all matters pertaining to the 2009 tax year and increased Entergy’s 2009 federal income tax liability by $2.4 million.

2010-2011 IRS Audit

The IRS examination of the 2010 and 2011 years is ongoing and the audit field work is expected to be completed by the end of the first quarter of 2016. The IRS has not issued any significant notices of proposed adjustments other than for the decommissioning liability position discussed above. The Revenue Agent’s Report is expected to be received shortly after the completion of field work.

Other Tax Matters

Entergy regularly negotiates with the IRS to achieve settlements.  The resolution of audit issues could result in significant changes to the amounts of unrecognized tax benefits in the next twelve months.

In September 2013 the U.S. Treasury Department and the IRS issued final regulations that provide guidance on the deductibility and capitalization of costs incurred associated with tangible property. Entergy and the Registrant Subsidiaries filed with the IRS an automatic application for change in accounting method which is in compliance with the final regulations and the safe harbor provisions of the relevant IRS Revenue Procedures. Entergy estimates that the effect of this accounting method change will result in a net increase to Entergy’s taxable income of approximately $585 million, which will be recognized generally over a four year period beginning with the tax year ended 2014. The adoption of the final regulations and safe harbor method results in approximate changes in the Registrant Subsidiaries taxable income as follows: an increase of $177 million for Entergy Arkansas, an increase of $78 million for Entergy Louisiana, an increase of $26 million for Entergy Mississippi, an increase of $183 million for Entergy Texas, a decrease of $2 million for Entergy New Orleans, and an increase of $22 million for System Energy.

In October 2015 two of Entergy’s Louisiana utilities, Entergy Gulf States Louisiana and Entergy Louisiana, combined their businesses into a legal entity which is identified as Entergy Louisiana herein. Entergy Louisiana maintained a carryover tax basis in the assets received. Additionally, the tax consequences provided for an increase in tax basis as well. To the extent that this increase in tax basis will provide additional tax depreciation, Entergy recorded a deferred tax asset and current tax expense resulting in a net increase in tax basis of approximately $334 million and Entergy Louisiana obtained a corresponding deferred tax asset. Consistent with the terms of an agreement with the LPSC, electric customers of Entergy Louisiana will realize customer credits associated with the business combination. Accordingly, in October 2015, Entergy recorded a regulatory liability of $107 million ($66 million net-of-tax) which partially offsets the effect of the aforementioned deferred tax asset. The deferred tax asset and the regulatory liability, net-of-tax, increased Entergy Louisiana’s member’s equity by $268 million. See Note 2 to the financial statements for further discussion of the business combination.

In the fourth quarter 2015, System Energy and Entergy Louisiana adopted a new method of accounting for income tax purposes in which the companies’ nuclear decommissioning costs will be treated as production costs of electricity includable in cost of goods sold. The new method results in a reduction of taxable income of $1.2 billion for System Energy and $2.2 billion for Entergy Louisiana.

The Protecting Americans from Tax Hikes Act of 2015 was enacted in December 2015. The most significant provisions affecting Entergy and the Registrant Subsidiaries were a five-year extension of bonus depreciation and permanent extension of the research and experimentation tax credit. The effect of the bonus depreciation extension on 2015 increased Entergy’s tax net operating loss.
Entergy New Orleans [Member]  
Income Taxes
INCOME TAXES (Entergy Corporation, Entergy Arkansas, Entergy Louisiana, Entergy Mississippi, Entergy New Orleans, Entergy Texas, and System Energy)

Income taxes for 2015, 2014, and 2013 for Entergy Corporation and Subsidiaries consist of the following:
 
2015
 
2014
 
2013
 
(In Thousands)
Current:
 
 
 
 
 
Federal

$77,166

 

$90,061

 

$88,291

Foreign
97

 
90

 
101

State
157,829

 
(12,637
)
 
20,584

Total
235,092

 
77,514

 
108,976

Deferred and non-current - net
(864,799
)
 
528,326

 
126,935

Investment tax credit adjustments - net
(13,220
)
 
(16,243
)
 
(9,930
)
Income taxes

($642,927
)
 

$589,597

 

$225,981



Income taxes for 2015, 2014, and 2013 for Entergy’s Registrant Subsidiaries consist of the following:
2015
 
Entergy
Arkansas
 
Entergy
Louisiana
 
Entergy
Mississippi
 
Entergy
New Orleans
 
Entergy
Texas
 
System
Energy
 
 
(In Thousands)
Current:
 
 
 
 
 
 
 
 
 
 
 
 
Federal
 

$66,966

 

$101,382

 

$25,628

 

($9,346
)
 

$53,313

 

($63,302
)
State
 
6,265

 
35,406

 
6,832

 
1,784

 
2,450

 
26,755

Total
 
73,231

 
136,788

 
32,460

 
(7,562
)
 
55,763

 
(36,547
)
Deferred and non-current - net
 
(31,463
)
 
47,220

 
31,149

 
32,890

 
(17,599
)
 
93,491

Investment tax credit adjustments - net
 
(1,227
)
 
(5,337
)
 
(1,737
)
 
(138
)
 
(914
)
 
(3,867
)
Income taxes
 

$40,541

 

$178,671

 

$61,872

 

$25,190

 

$37,250

 

$53,077


2014
 
Entergy
Arkansas
 
Entergy
Louisiana
 
Entergy
Mississippi
 
Entergy
New Orleans
 
Entergy
Texas
 
System
Energy
 
 
(In Thousands)
Current:
 
 
 
 
 
 
 
 
 
 
 
 
Federal
 

($34,258
)
 

($44,909
)
 

$8,103

 

($1,428
)
 

$48,610

 

$19,908

State
 
(678
)
 
(1,191
)
 
7,474

 
510

 
4,877

 
15,379

Total
 
(34,936
)
 
(46,100
)
 
15,577

 
(918
)
 
53,487

 
35,287

Deferred and non-current - net
 
119,841

 
236,794

 
42,305

 
14,592

 
(2,418
)
 
53,501

Investment tax credit adjustments - net
 
(1,276
)
 
(5,642
)
 
(2,172
)
 
(224
)
 
(1,425
)
 
(5,478
)
Income taxes
 

$83,629

 

$185,052

 

$55,710

 

$13,450

 

$49,644

 

$83,310


2013
 
Entergy
Arkansas
 
Entergy
Louisiana
 
Entergy
Mississippi
 
Entergy
New Orleans
 
Entergy
Texas
 
System
Energy
 
 
(In Thousands)
Current:
 
 
 
 
 
 
 
 
 
 
 
 
Federal
 

($13,574
)
 

($18,797
)
 

$2,498

 

$14,823

 

$37,199

 

($6,199
)
State
 
6,122

 
(15,631
)
 
4,849

 
(1,267
)
 
(843
)
 
15,845

Total
 
(7,452
)
 
(34,428
)
 
7,347

 
13,556

 
36,356

 
9,646

Deferred and non-current - net
 
101,253

 
179,036

 
41,150

 
(11,033
)
 
(4,639
)
 
60,614

Investment tax credit adjustments - net
 
(2,014
)
 
(5,912
)
 
1,260

 
(246
)
 
(1,609
)
 
(1,407
)
Income taxes
 

$91,787

 

$138,696

 

$49,757

 

$2,277

 

$30,108

 

$68,853



Total income taxes for Entergy Corporation and Subsidiaries differ from the amounts computed by applying the statutory income tax rate to income before income taxes.  The reasons for the differences for the years 2015, 2014, and 2013 are:
 
2015
 
2014
 
2013
 
(In Thousands)
Net income (loss) attributable to Entergy Corporation

($176,562
)
 

$940,721

 

$711,902

Preferred dividend requirements of subsidiaries
19,828

 
19,536

 
18,670

Consolidated net income (loss)
(156,734
)
 
960,257

 
730,572

Income taxes
(642,927
)
 
589,597

 
225,981

Income (loss) before income taxes

($799,661
)
 

$1,549,854

 

$956,553

Computed at statutory rate (35%)

($279,881
)
 

$542,449

 

$334,794

Increases (reductions) in tax resulting from:
 

 
 

 
 

State income taxes net of federal income tax effect
29,944

 
44,708

 
13,599

Regulatory differences - utility plant items
32,089

 
39,321

 
32,324

Equity component of AFUDC
(18,191
)
 
(21,108
)
 
(22,356
)
Amortization of investment tax credits
(11,136
)
 
(12,211
)
 
(13,535
)
Flow-through / permanent differences
(7,872
)
 
(18,003
)
 
(301
)
Net-of-tax regulatory liability

 

 
(2,899
)
New York tax law change (a)

 
(21,500
)
 

Louisiana business combination
(333,655
)
 

 

Termination of business reorganization

 

 
(27,192
)
Provision for uncertain tax positions (b)
(56,683
)
 
32,573

 
(59,249
)
Valuation allowance

 

 
(31,573
)
Other - net
2,458

 
3,368

 
2,369

Total income taxes as reported

($642,927
)
 

$589,597

 

$225,981

Effective Income Tax Rate
80.4
%
 
38.0
%
 
23.6
%


(a)
In March 2014, New York enacted legislation that substantially modifies various aspects of New York tax law. The most significant effect of the legislation for Entergy is the adoption of full water’s-edge unitary combined reporting, meaning that all of Entergy’s domestic entities will be included in New York’s combined filing group. The effect of the tax law change resulted in a deferred state income tax reduction of approximately $21.5 million as shown in the table above.
(b)
See “Income Tax Audits - 2008-2009 IRS Audit” below for discussion of the most significant items for 2015 and 2013.

Total income taxes for the Registrant Subsidiaries differ from the amounts computed by applying the statutory income tax rate to income before taxes.  The reasons for the differences for the years 2015, 2014, and 2013 are:
2015
 
Entergy
Arkansas
 
Entergy
Louisiana
 
Entergy
Mississippi
 
Entergy
New Orleans
 
Entergy
Texas
 
System
Energy
 
 
(In Thousands)
Net income
 

$74,272

 

$446,639

 

$92,708

 

$44,925

 

$69,625

 

$111,318

Income taxes
 
40,541

 
178,671

 
61,872

 
25,190

 
37,250

 
53,077

Pretax income
 

$114,813

 

$625,310

 

$154,580

 

$70,115

 

$106,875

 

$164,395

Computed at statutory rate (35%)
 

$40,185

 

$218,859

 

$54,103

 

$24,540

 

$37,406

 

$57,538

Increases (reductions) in tax resulting from:
 
 
 
 

 
 

 
 

 
 

 
 

State income taxes net of federal income tax effect
 
6,643

 
23,650

 
5,219

 
2,887

 
1,621

 
6,403

Regulatory differences - utility plant items
 
7,299

 
3,013

 
2,383

 
2,201

 
3,703

 
12,167

Equity component of AFUDC
 
(4,979
)
 
(5,420
)
 
(1,083
)
 
(451
)
 
(1,987
)
 
(2,973
)
Amortization of investment tax credits
 
(1,201
)
 
(5,252
)
 
(160
)
 
(111
)
 
(900
)
 
(3,476
)
Flow-through / permanent differences
 
(4,062
)
 
2,460

 
431

 
(4,539
)
 
530

 
618

Non-taxable dividend income
 

 
(44,658
)
 

 

 

 

Provision for uncertain tax positions (a)
 
(3,978
)
 
(15,377
)
 
756

 
525

 
(3,365
)
 
(17,313
)
Other - net
 
634

 
1,396

 
223

 
138

 
242

 
113

Total income taxes
 

$40,541

 

$178,671

 

$61,872

 

$25,190

 

$37,250

 

$53,077

Effective Income Tax Rate
 
35.3
%
 
28.6
%
 
40.0
%
 
35.9
%
 
34.9
%
 
32.3
%


(a)
See “Income Tax Audits - 2008-2009 IRS Audit” below for discussion of the most significant items for Entergy Louisiana and System Energy.

2014
 
Entergy
Arkansas
 
Entergy
Louisiana
 
Entergy
Mississippi
 
Entergy
New Orleans
 
Entergy
Texas
 
System
Energy
 
 
(In Thousands)
Net income
 

$121,392

 

$446,022

 

$74,821

 

$31,030

 

$74,804

 

$96,334

Income taxes
 
83,629

 
185,052

 
55,710

 
13,450

 
49,644

 
83,310

Pretax income
 

$205,021

 

$631,074

 

$130,531

 

$44,480

 

$124,448

 

$179,644

Computed at statutory rate (35%)
 

$71,757

 

$220,876

 

$45,686

 

$15,568

 

$43,557

 

$62,875

Increases (reductions) in tax resulting from:
 
 

 
 

 
 

 
 

 
 

 
 

State income taxes net of federal income tax effect
 
9,591

 
11,666

 
5,180

 
1,562

 
3,221

 
6,877

Regulatory differences - utility plant items
 
8,653

 
7,487

 
4,448

 
777

 
4,165

 
13,791

Equity component of AFUDC
 
(2,533
)
 
(14,612
)
 
(833
)
 
(320
)
 
(1,035
)
 
(1,774
)
Amortization of investment tax credits
 
(1,251
)
 
(5,594
)
 
(260
)
 
(218
)
 
(1,412
)
 
(3,476
)
Flow-through / permanent differences
 
(5,082
)
 
(225
)
 
555

 
(4,458
)
 
393

 
(327
)
Non-taxable dividend income
 

 
(41,255
)
 

 

 

 

Provision for uncertain tax positions
 
1,881

 
5,336

 
718

 
405

 
522

 
5,235

Other - net
 
613

 
1,373

 
216

 
134

 
233

 
109

Total income taxes
 

$83,629

 

$185,052

 

$55,710

 

$13,450

 

$49,644

 

$83,310

Effective Income Tax Rate
 
40.8
%
 
29.3
%
 
42.7
%
 
30.2
%
 
39.9
%
 
46.4
%


2013
 
Entergy
Arkansas
 
Entergy
Louisiana
 
Entergy
Mississippi
 
Entergy
New Orleans
 
Entergy
Texas
 
System
Energy
 
 
(In Thousands)
Net income
 

$161,948

 

$414,126

 

$82,159

 

$12,608

 

$57,881

 

$113,664

Income taxes
 
91,787

 
138,696

 
49,757

 
2,277

 
30,108

 
68,853

Pretax income
 

$253,735

 

$552,822

 

$131,916

 

$14,885

 

$87,989

 

$182,517

Computed at statutory rate (35%)
 

$88,807

 

$193,488

 

$46,171

 

$5,210

 

$30,796

 

$63,881

Increases (reductions) in tax resulting from:
 
 

 
 

 
 

 
 

 
 

 
 

State income taxes net of federal income tax effect
 
10,954

 
19,084

 
4,564

 
1,116

 
(897
)
 
5,900

Regulatory differences - utility plant items
 
7,938

 
7,005

 
2,603

 
453

 
3,256

 
11,070

Equity component of AFUDC
 
(3,820
)
 
(13,100
)
 
(764
)
 
(322
)
 
(1,626
)
 
(2,724
)
Amortization of investment tax credits
 
(1,989
)
 
(5,864
)
 
(260
)
 
(216
)
 
(1,596
)
 
(3,476
)
Flow-through / permanent differences
 
2,540

 
3,646

 
1,702

 
(4,402
)
 
2,467

 
(491
)
Net-of-tax regulatory liability
 

 
(2,899
)
 

 

 

 

Termination of business organization
 
(6,753
)
 
(7,453
)
 
(4,177
)
 
(501
)
 
(3,542
)
 
(13
)
Non-taxable dividend income
 

 
(36,953
)
 

 

 

 

Provision for uncertain tax positions (a)
 
(6,527
)
 
(18,645
)
 
(326
)
 
795

 
1,027

 
(5,353
)
Other - net
 
637

 
387

 
244

 
144

 
223

 
59

Total income taxes
 

$91,787

 

$138,696

 

$49,757

 

$2,277

 

$30,108

 

$68,853

Effective Income Tax Rate
 
36.2
%
 
25.1
%
 
37.7
%
 
15.3
%
 
34.2
%
 
37.7
%


(a)
See “Income Tax Audits - 2008-2009 IRS Audit” below for discussion of the most significant items for Entergy Louisiana and System Energy.

Significant components of accumulated deferred income taxes and taxes accrued for Entergy Corporation and Subsidiaries as of December 31, 2015 and 2014 are as follows:
 
 
2015
 
2014
 
(In Thousands)
Deferred tax liabilities:
 
 
 
Plant basis differences - net

($6,804,225
)
 

($8,128,096
)
Regulatory assets
(646,392
)
 
(922,161
)
Nuclear decommissioning trusts
(1,254,463
)
 
(1,248,737
)
Pension, net funding
(365,111
)
 
(324,881
)
Combined unitary state taxes
(45,078
)
 
(162,340
)
Power purchase agreements

 
(110,889
)
Other
(315,844
)
 
(500,424
)
Total
(9,431,113
)
 
(11,397,528
)
Deferred tax assets:
 

 
 

Nuclear decommissioning liabilities
828,983

 
874,493

Regulatory liabilities
284,432

 
458,230

Pension and other post-employment benefits
525,524

 
586,455

Sale and leaseback
139,720

 
153,308

Compensation
69,432

 
74,692

Accumulated deferred investment tax credit
95,248

 
100,442

Provision for allowances and contingencies
188,282

 
160,551

Power purchase agreements
38,401

 

Net operating loss carryforwards
360,188

 
457,758

Capital losses and miscellaneous tax credits
11,075

 
12,146

Valuation allowance
(91,532
)
 
(27,387
)
Other
68,204

 
58,334

Total
2,517,957

 
2,909,022

Non-current accrued taxes (including unrecognized tax benefits)
(1,338,806
)
 
(606,560
)
Accumulated deferred income taxes and taxes accrued

($8,251,962
)
 

($9,095,066
)


Entergy’s estimated tax attributes carryovers and their expiration dates as of December 31, 2015 are as follows:
Carryover Description
 
Carryover Amount
 
Year(s) of expiration
 
 
 
 
 
Federal net operating losses
 
$3.6 billion
 
2023-2035
State net operating losses
 
$5.2 billion
 
2016-2035
Miscellaneous federal and state credits
 
$77.9 million
 
2016-2035


As a result of the accounting for uncertain tax positions, the amount of the deferred tax assets reflected in the financial statements is less than the amount of the tax effect of the federal and state net operating loss carryovers, tax credit carryovers, and other tax attributes reflected on income tax returns. Because it is more likely than not that the benefit from certain state net operating loss carryovers will not be utilized, valuation allowances of $46 million as of December 31, 2015 and $21 million as of December 31, 2014 have been provided on the deferred tax assets relating to these state net operating loss carryovers. Additionally, valuation allowances totaling $45.5 million as of December 31, 2015 have been provided on deferred tax assets related to state jurisdictions in which Entergy does not currently expect to be able to utilize separate company tax return losses, preventing realization of such deferred tax assets.
Significant components of accumulated deferred income taxes and taxes accrued for the Registrant Subsidiaries as of December 31, 2015 and 2014 are as follows:
2015
Entergy
Arkansas
 
Entergy
Louisiana
 
Entergy
Mississippi
 
Entergy
New Orleans
 
Entergy
Texas
 
System
Energy
 
(In Thousands)
Deferred tax liabilities:
 
 
 
 
 
 
 
 
 
 
 
Plant basis differences - net

($1,710,444
)
 

($2,041,968
)
 

($781,427
)
 

($167,294
)
 

($778,270
)
 

($611,745
)
Regulatory assets
(108,422
)
 
(254,316
)
 
(24,918
)
 
(39,451
)
 
(172,117
)
 
(46,990
)
Nuclear decommissioning trusts
(121,326
)
 
(99,980
)
 

 

 

 
(68,370
)
Pension, net funding
(107,073
)
 
(109,709
)
 
(30,901
)
 
(14,459
)
 
(28,001
)
 
(25,791
)
Deferred fuel
(7,647
)
 
(2,513
)
 
(684
)
 
(175
)
 
2,050

 
(18
)
Other
(38,683
)
 
(86,275
)
 
(5,625
)
 
(12,253
)
 
(10,109
)
 
(22,478
)
Total
(2,093,595
)
 
(2,594,761
)
 
(843,555
)
 
(233,632
)
 
(986,447
)
 
(775,392
)
Deferred tax assets:
 

 
 

 
 

 
 

 
 

 
 

Regulatory liabilities
18,369

 
215,154

 
7,787

 
20,888

 
7,307

 
14,927

Nuclear decommissioning liabilities
109,962

 
49,333

 

 

 

 
39,420

Pension and other post-employment benefits
(20,420
)
 
149,680

 
(6,628
)
 
(8,939
)
 
(16,703
)
 
(1,037
)
Sale and leaseback

 
37,236

 

 

 

 
102,484

Accumulated deferred investment tax credit
14,320

 
56,635

 
1,777

 
290

 
4,842

 
17,385

Provision for allowances and contingencies
1,024

 
123,007

 
18,735

 
33,843

 
7,266

 
134

Power purchase agreements
(1,279
)
 
13,840

 
1,901

 
13

 
575

 

Unbilled/deferred revenues
9,815

 
(32,365
)
 
7,154

 
2,126

 
10,851

 

Compensation
1,842

 
4,182

 
601

 
880

 
4,496

 

Net operating loss carryforwards

 
90,241

 

 

 

 

Other
128

 
21,982

 
1,995

 
316

 
1,672

 

Total
133,761

 
728,925

 
33,322

 
49,417

 
20,306

 
173,313

Non-current accrued taxes (including unrecognized tax benefits)
(22,978
)
 
(641,120
)
 
(402
)
 
(29,846
)
 
(40,693
)
 
(416,996
)
Accumulated deferred income taxes and taxes accrued

($1,982,812
)
 

($2,506,956
)
 

($810,635
)
 

($214,061
)
 

($1,006,834
)
 

($1,019,075
)
2014
 
Entergy
Arkansas
 
Entergy
Louisiana
 
Entergy
Mississippi
 
Entergy
New Orleans
 
Entergy
Texas
 
System
Energy
 
 
(In Thousands)
Deferred tax liabilities:
 
 
 
 
 
 
 
 
 
 
 
 
Plant basis differences - net
 

($1,657,503
)
 

($2,748,852
)
 

($753,576
)
 

($186,153
)
 

($771,135
)
 

($668,779
)
Regulatory assets
 
(198,662
)
 
(380,719
)
 
(30,114
)
 

 
(202,402
)
 
(110,087
)
Nuclear decommissioning trusts
 
(130,524
)
 
(106,162
)
 

 

 

 
(74,063
)
Pension, net funding
 
(93,355
)
 
(99,593
)
 
(27,861
)
 
(13,285
)
 
(25,616
)
 
(23,440
)
Deferred fuel
 
(82,050
)
 
(3,534
)
 
(5,303
)
 
(407
)
 
2,045

 
(120
)
Power purchase agreements
 
(17,073
)
 
(67,083
)
 
2,129

 
13

 
847

 

Other
 
(33,827
)
 
(84,282
)
 
(11,423
)
 
(11,500
)
 
(22,546
)
 
(19,802
)
Total
 
(2,212,994
)
 
(3,490,225
)
 
(826,148
)
 
(211,332
)
 
(1,018,807
)
 
(896,291
)
Deferred tax assets:
 
 

 
 

 
 

 
 

 
 

 
 

Regulatory liabilities
 
145,466

 
181,601

 
7,214

 
29,580

 
4,079

 
90,290

Nuclear decommissioning liabilities
 
(43,134
)
 
146,138

 

 

 

 
(62,571
)
Pension and other post-employment benefits
 
(17,534
)
 
158,661

 
(7,288
)
 
(7,504
)
 
(15,053
)
 
(1,413
)
Sale and leaseback
 

 
45,136

 

 

 

 
108,172

Accumulated deferred investment tax credit
 
14,791

 
58,863

 
2,436

 
332

 
5,158

 
18,862

Provision for allowances and contingencies
 
(7,149
)
 
125,805

 
19,590

 
10,986

 
8,017

 
133

Unbilled/deferred revenues
 
12,322

 
(25,016
)
 
12,956

 
3,395

 
11,573

 

Compensation
 
2,085

 
158

 
(846
)
 
475

 
4,155

 

Net operating loss carryforwards
 
105,063

 
241,803

 

 

 

 

Capital losses and miscellaneous tax credits
 

 

 
3,504

 

 

 

Other
 
258

 
15,508

 
5,887

 
2,891

 
3,850

 
2,000

Total
 
212,168

 
948,657

 
43,453

 
40,155

 
21,779

 
155,473

Non-current accrued taxes (including unrecognized tax benefits)
 
9,367

 
(412,508
)
 
(12,481
)
 
(19,502
)
 
(48,921
)
 
(81,528
)
Accumulated deferred income taxes and taxes accrued
 

($1,991,459
)
 

($2,954,076
)
 

($795,176
)
 

($190,679
)
 

($1,045,949
)
 

($822,346
)


The Registrant Subsidiaries’ estimated tax attributes carryovers and their expiration dates as of December 31, 2015 are as follows:
 
 
 
Entergy
Arkansas
 
 
Entergy
Louisiana
 
 
Entergy
Mississippi
 
Entergy
New Orleans
 
 
Entergy
Texas
 
 
System
Energy
 
 
 
 
 
 
 
 
 
 
 
 
 
Federal net operating losses
 
$7 million
 
$2.4 billion
 
 
 
 
$242 million
Year(s) of expiration
 
2030-2035
 
2035
 
N/A
 
N/A
 
N/A
 
2030-2035
 
 
 
 
 
 
 
 
 
 
 
 
 
State net operating losses
 
 
$2.5 billion
 
 
$6 million
 
 
$833 million
Year(s) of expiration
 
N/A
 
2035
 
N/A
 
2032
 
N/A
 
2035
 
 
 
 
 
 
 
 
 
 
 
 
 
Misc. federal credits
 
$1 million
 
 
$1 million
 
 
 
$1 million
Year(s) of expiration
 
2029-2033
 
N/A
 
2029-2034
 
N/A
 
N/A
 
2029-2033
 
 
 
 
 
 
 
 
 
 
 
 
 
State credits
 
 
 
 
 
$3.3 million
 
$6 million
Year(s) of expiration
 
N/A
 
N/A
 
N/A
 
N/A
 
2026
 
2017-2020


As a result of the accounting for uncertain tax positions, the amount of the deferred tax assets reflected in the financial statements is less than the amount of the tax effect of the federal and state net operating loss carryovers and tax credit carryovers.

Unrecognized tax benefits

Accounting standards establish a “more-likely-than-not” recognition threshold that must be met before a tax benefit can be recognized in the financial statements.  If a tax deduction is taken on a tax return, but does not meet the more-likely-than-not recognition threshold, an increase in income tax liability, above what is payable on the tax return, is required to be recorded.  A reconciliation of Entergy’s beginning and ending amount of unrecognized tax benefits is as follows:
 
2015
 
2014
 
2013
 
(In Thousands)
Gross balance at January 1

$4,736,785

 

$4,593,224

 

$4,170,403

Additions based on tax positions related to the current year
1,850,705

 
348,543

 
162,338

Additions for tax positions of prior years
59,815

 
11,637

 
410,108

Reductions for tax positions of prior years (a)
(3,966,535
)
 
(213,401
)
 
(103,360
)
Settlements
(68,227
)
 

 
(43,620
)
Lapse of statute of limitations
(958
)
 
(3,218
)
 
(2,645
)
Gross balance at December 31
2,611,585

 
4,736,785

 
4,593,224

Offsets to gross unrecognized tax benefits:
 

 
 

 
 

Credit and loss carryovers
(1,264,483
)
 
(4,295,643
)
 
(4,400,498
)
Unrecognized tax benefits net of unused tax attributes and payments (b)

$1,347,102

 

$441,142

 

$192,726



(a)
The primary reduction is related to the nuclear decommissioning costs treatment discussed in “Income Tax Audits - 2008-2009 IRS Audit” below.
(b)
Potential tax liability above what is payable on tax returns

The balances of unrecognized tax benefits include $955 million, $516 million, and $176 million as of December 31, 2015, 2014, and 2013, respectively, which, if recognized, would lower the effective income tax rates.  Because of the effect of deferred tax accounting, the remaining balances of unrecognized tax benefits of $1.657 billion, $4.221 billion, and $4.417 billion as of December 31, 2015, 2014, and 2013, respectively, if disallowed, would not affect the annual effective income tax rate but would accelerate the payment of cash to the taxing authority to an earlier period.

Entergy accrues interest expense, if any, related to unrecognized tax benefits in income tax expense.  Entergy’s December 31, 2015, 2014, and 2013 accrued balance for the possible payment of interest is approximately $27 million, $127 million, and $96.4 million, respectively.

A reconciliation of the Registrant Subsidiaries’ beginning and ending amount of unrecognized tax benefits for 2015, 2014, and 2013 is as follows:
2015
 
Entergy
Arkansas
 
Entergy
Louisiana
 
Entergy
Mississippi
 
Entergy
New Orleans
 
Entergy
Texas
 
System
Energy
 
 
(In Thousands)
Gross balance at January 1, 2015
 

$362,912

 

$1,205,929

 

$20,144

 

$53,763

 

$17,264

 

$258,242

Additions based on tax positions related to the current year (a)
 
2,196

 
1,367,058

 
566

 
472

 
657

 
472,304

Additions for tax positions of prior years
 
1,057

 
7,992

 
8,140

 
48

 
2,914

 
913

Reductions for tax positions of prior years
 
(340,720
)
 
(859,430
)
 

 
(386
)
 
(3,981
)
 
(253,141
)
Settlements
 

 
(30,888
)
 
(9,368
)
 

 
(3,392
)
 

Gross balance at December 31, 2015
 
25,445

 
1,690,661

 
19,482

 
53,897

 
13,462

 
478,318

Offsets to gross unrecognized tax benefits:
 
 

 
 

 
 

 
 

 
 

 
 

Loss carryovers
 
(3,613
)
 
(893,764
)
 
(1,016
)
 
(506
)
 
(276
)
 
(133,611
)
Unrecognized tax benefits net of unused tax attributes and payments
 

$21,832

 

$796,897

 

$18,466

 

$53,391

 

$13,186

 

$344,707



(a)
The primary addition for Entergy Louisiana and System Energy is related to the nuclear decommissioning costs treatment discussed in “Other Tax Matters” below.

2014
 
Entergy
Arkansas
 
Entergy
Louisiana
 
Entergy
Mississippi
 
Entergy
New Orleans
 
Entergy
Texas
 
System
Energy
 
 
(In Thousands)
Gross balance at January 1, 2014
 

$347,713

 

$1,076,680

 

$16,186

 

$51,679

 

$13,017

 

$265,185

Additions based on tax positions related to the current year
 
14,511

 
151,249

 
3,928

 
2,235

 
4,225

 
2,744

Additions for tax positions of prior years
 
1,767

 
6,924

 
319

 
37

 
303

 
566

Reductions for tax positions of prior years
 
(1,079
)
 
(28,924
)
 
(289
)
 
(188
)
 
(267
)
 
(10,253
)
Settlements
 

 

 

 

 
(14
)
 

Gross balance at December 31, 2014
 
362,912

 
1,205,929

 
20,144

 
53,763

 
17,264

 
258,242

Offsets to gross unrecognized tax benefits:
 
 

 
 

 
 

 
 

 
 

 
 

Loss carryovers
 
(361,043
)
 
(739,988
)
 
(6,992
)
 
(20,735
)
 
(241
)
 
(163,124
)
Unrecognized tax benefits net of unused tax attributes and payments
 

$1,869

 

$465,941

 

$13,152

 

$33,028

 

$17,023

 

$95,118


2013
 
Entergy
Arkansas
 
Entergy
Louisiana
 
Entergy
Mississippi
 
Entergy
New Orleans
 
Entergy
Texas
 
System
Energy
 
 
(In Thousands)
Gross balance at January 1, 2013
 

$344,669

 

$1,002,394

 

$16,841

 

$52,018

 

$13,954

 

$260,346

Additions based on tax positions related to the current year
 
6,427

 
17,887

 
957

 
583

 
2,170

 
4,170

Additions for tax positions of prior years
 
1,228

 
125,214

 
401

 
3,506

 
587

 
8,391

Reductions for tax positions of prior years
 
(3,943
)
 
(53,473
)
 
(1,941
)
 
(962
)
 
(4,186
)
 
(967
)
Settlements
 
(668
)
 
(15,342
)
 
(72
)
 
(3,466
)
 
492

 
(6,755
)
Gross balance at December 31, 2013
 
347,713

 
1,076,680

 
16,186

 
51,679

 
13,017

 
265,185

Offsets to gross unrecognized tax benefits:
 
 

 
 

 
 

 
 

 
 

 
 

Loss carryovers
 
(345,674
)
 
(747,756
)
 
(16,186
)
 
(22,078
)
 
(266
)
 
(225,286
)
Unrecognized tax benefits net of unused tax attributes and payments
 

$2,039

 

$328,924

 

$—

 

$29,601

 

$12,751

 

$39,899



The Registrant Subsidiaries’ balances of unrecognized tax benefits included amounts which, if recognized, would have reduced income tax expense as follows:
 
December 31,
 
2015
 
2014
 
2013
 
(In Millions)
Entergy Arkansas

$4.5

 

$2.6

 

$0.6

Entergy Louisiana

$692.7

 

$267.3

 

$131.9

Entergy Mississippi

$8.1

 

$3.9

 

$3.9

Entergy New Orleans

$50.7

 

$50.7

 

$—

Entergy Texas

$5.2

 

$10.5

 

$10.1

System Energy

$0.7

 

$3.7

 

$3.3



The Registrant Subsidiaries accrue interest and penalties related to unrecognized tax benefits in income tax expense.  Penalties have not been accrued.  Accrued balances for the possible payment of interest are as follows:
 
December 31,
 
2015
 
2014
 
2013
 
(In Millions)
Entergy Arkansas

$1.3

 

$17.0

 

$15.2

Entergy Louisiana

$9.3

 

$22.2

 

$18.0

Entergy Mississippi

$0.4

 

$2.8

 

$2.1

Entergy New Orleans

$1.8

 

$1.3

 

$0.9

Entergy Texas

$1.2

 

$1.0

 

$0.8

System Energy

$0.7

 

$23.8

 

$19.0



Income Tax Audits

Entergy and its subsidiaries file U.S. federal and various state and foreign income tax returns.  IRS examinations are complete for years before 2010. All state taxing authorities’ examinations are completed for years before 2009.

2006-2007 IRS Audit

In the first quarter 2015, the IRS finalized tax and interest computations from the 2006-2007 audit that resulted in a reversal of Entergy’s provision for uncertain tax positions related to accrued interest of approximately $20 million, including decreases of approximately $4 million for Entergy Arkansas, $11 million for Entergy Louisiana, and $1 million for System Energy.

2008-2009 IRS Audit

In the fourth quarter 2009, Entergy filed Applications for Change in Accounting Method (the “2009 CAM”) for tax purposes with the IRS for certain costs under Section 263A of the Internal Revenue Code.  In the Applications, Entergy proposed to treat the nuclear decommissioning liability associated with the operation of its nuclear power plants as a production cost properly includable in cost of goods sold.  The effect of the 2009 CAM was a $5.7 billion reduction in 2009 taxable income.  The 2009 CAM was adjusted to $9.3 billion in 2012.

In the fourth quarter 2012 the IRS disallowed the reduction to 2009 taxable income related to the 2009 CAM.  In the third quarter 2013, the Internal Revenue Service issued its RAR for the tax years 2008-2009. As a result of the issuance of this RAR, Entergy and the IRS resolved all of the 2008-2009 issues described above except for the 2009 CAM. Entergy disagreed with the IRS’s disallowance of the 2009 CAM and filed a protest with the IRS Appeals Division in October 2013.

In August 2015, Entergy and the IRS agreed on the treatment of the 2009 position regarding nuclear decommissioning liabilities from the 2008-2009 audit. The agreement provides that Entergy is entitled to deduct approximately $118 million of the $9.3 billion claimed in 2009. The agreement effectively settled all matters pertaining to the 2009 tax year and increased Entergy’s 2009 federal income tax liability by $2.4 million.

2010-2011 IRS Audit

The IRS examination of the 2010 and 2011 years is ongoing and the audit field work is expected to be completed by the end of the first quarter of 2016. The IRS has not issued any significant notices of proposed adjustments other than for the decommissioning liability position discussed above. The Revenue Agent’s Report is expected to be received shortly after the completion of field work.

Other Tax Matters

Entergy regularly negotiates with the IRS to achieve settlements.  The resolution of audit issues could result in significant changes to the amounts of unrecognized tax benefits in the next twelve months.

In September 2013 the U.S. Treasury Department and the IRS issued final regulations that provide guidance on the deductibility and capitalization of costs incurred associated with tangible property. Entergy and the Registrant Subsidiaries filed with the IRS an automatic application for change in accounting method which is in compliance with the final regulations and the safe harbor provisions of the relevant IRS Revenue Procedures. Entergy estimates that the effect of this accounting method change will result in a net increase to Entergy’s taxable income of approximately $585 million, which will be recognized generally over a four year period beginning with the tax year ended 2014. The adoption of the final regulations and safe harbor method results in approximate changes in the Registrant Subsidiaries taxable income as follows: an increase of $177 million for Entergy Arkansas, an increase of $78 million for Entergy Louisiana, an increase of $26 million for Entergy Mississippi, an increase of $183 million for Entergy Texas, a decrease of $2 million for Entergy New Orleans, and an increase of $22 million for System Energy.

In October 2015 two of Entergy’s Louisiana utilities, Entergy Gulf States Louisiana and Entergy Louisiana, combined their businesses into a legal entity which is identified as Entergy Louisiana herein. Entergy Louisiana maintained a carryover tax basis in the assets received. Additionally, the tax consequences provided for an increase in tax basis as well. To the extent that this increase in tax basis will provide additional tax depreciation, Entergy recorded a deferred tax asset and current tax expense resulting in a net increase in tax basis of approximately $334 million and Entergy Louisiana obtained a corresponding deferred tax asset. Consistent with the terms of an agreement with the LPSC, electric customers of Entergy Louisiana will realize customer credits associated with the business combination. Accordingly, in October 2015, Entergy recorded a regulatory liability of $107 million ($66 million net-of-tax) which partially offsets the effect of the aforementioned deferred tax asset. The deferred tax asset and the regulatory liability, net-of-tax, increased Entergy Louisiana’s member’s equity by $268 million. See Note 2 to the financial statements for further discussion of the business combination.

In the fourth quarter 2015, System Energy and Entergy Louisiana adopted a new method of accounting for income tax purposes in which the companies’ nuclear decommissioning costs will be treated as production costs of electricity includable in cost of goods sold. The new method results in a reduction of taxable income of $1.2 billion for System Energy and $2.2 billion for Entergy Louisiana.

The Protecting Americans from Tax Hikes Act of 2015 was enacted in December 2015. The most significant provisions affecting Entergy and the Registrant Subsidiaries were a five-year extension of bonus depreciation and permanent extension of the research and experimentation tax credit. The effect of the bonus depreciation extension on 2015 increased Entergy’s tax net operating loss.
Entergy Texas [Member]  
Income Taxes
INCOME TAXES (Entergy Corporation, Entergy Arkansas, Entergy Louisiana, Entergy Mississippi, Entergy New Orleans, Entergy Texas, and System Energy)

Income taxes for 2015, 2014, and 2013 for Entergy Corporation and Subsidiaries consist of the following:
 
2015
 
2014
 
2013
 
(In Thousands)
Current:
 
 
 
 
 
Federal

$77,166

 

$90,061

 

$88,291

Foreign
97

 
90

 
101

State
157,829

 
(12,637
)
 
20,584

Total
235,092

 
77,514

 
108,976

Deferred and non-current - net
(864,799
)
 
528,326

 
126,935

Investment tax credit adjustments - net
(13,220
)
 
(16,243
)
 
(9,930
)
Income taxes

($642,927
)
 

$589,597

 

$225,981



Income taxes for 2015, 2014, and 2013 for Entergy’s Registrant Subsidiaries consist of the following:
2015
 
Entergy
Arkansas
 
Entergy
Louisiana
 
Entergy
Mississippi
 
Entergy
New Orleans
 
Entergy
Texas
 
System
Energy
 
 
(In Thousands)
Current:
 
 
 
 
 
 
 
 
 
 
 
 
Federal
 

$66,966

 

$101,382

 

$25,628

 

($9,346
)
 

$53,313

 

($63,302
)
State
 
6,265

 
35,406

 
6,832

 
1,784

 
2,450

 
26,755

Total
 
73,231

 
136,788

 
32,460

 
(7,562
)
 
55,763

 
(36,547
)
Deferred and non-current - net
 
(31,463
)
 
47,220

 
31,149

 
32,890

 
(17,599
)
 
93,491

Investment tax credit adjustments - net
 
(1,227
)
 
(5,337
)
 
(1,737
)
 
(138
)
 
(914
)
 
(3,867
)
Income taxes
 

$40,541

 

$178,671

 

$61,872

 

$25,190

 

$37,250

 

$53,077


2014
 
Entergy
Arkansas
 
Entergy
Louisiana
 
Entergy
Mississippi
 
Entergy
New Orleans
 
Entergy
Texas
 
System
Energy
 
 
(In Thousands)
Current:
 
 
 
 
 
 
 
 
 
 
 
 
Federal
 

($34,258
)
 

($44,909
)
 

$8,103

 

($1,428
)
 

$48,610

 

$19,908

State
 
(678
)
 
(1,191
)
 
7,474

 
510

 
4,877

 
15,379

Total
 
(34,936
)
 
(46,100
)
 
15,577

 
(918
)
 
53,487

 
35,287

Deferred and non-current - net
 
119,841

 
236,794

 
42,305

 
14,592

 
(2,418
)
 
53,501

Investment tax credit adjustments - net
 
(1,276
)
 
(5,642
)
 
(2,172
)
 
(224
)
 
(1,425
)
 
(5,478
)
Income taxes
 

$83,629

 

$185,052

 

$55,710

 

$13,450

 

$49,644

 

$83,310


2013
 
Entergy
Arkansas
 
Entergy
Louisiana
 
Entergy
Mississippi
 
Entergy
New Orleans
 
Entergy
Texas
 
System
Energy
 
 
(In Thousands)
Current:
 
 
 
 
 
 
 
 
 
 
 
 
Federal
 

($13,574
)
 

($18,797
)
 

$2,498

 

$14,823

 

$37,199

 

($6,199
)
State
 
6,122

 
(15,631
)
 
4,849

 
(1,267
)
 
(843
)
 
15,845

Total
 
(7,452
)
 
(34,428
)
 
7,347

 
13,556

 
36,356

 
9,646

Deferred and non-current - net
 
101,253

 
179,036

 
41,150

 
(11,033
)
 
(4,639
)
 
60,614

Investment tax credit adjustments - net
 
(2,014
)
 
(5,912
)
 
1,260

 
(246
)
 
(1,609
)
 
(1,407
)
Income taxes
 

$91,787

 

$138,696

 

$49,757

 

$2,277

 

$30,108

 

$68,853



Total income taxes for Entergy Corporation and Subsidiaries differ from the amounts computed by applying the statutory income tax rate to income before income taxes.  The reasons for the differences for the years 2015, 2014, and 2013 are:
 
2015
 
2014
 
2013
 
(In Thousands)
Net income (loss) attributable to Entergy Corporation

($176,562
)
 

$940,721

 

$711,902

Preferred dividend requirements of subsidiaries
19,828

 
19,536

 
18,670

Consolidated net income (loss)
(156,734
)
 
960,257

 
730,572

Income taxes
(642,927
)
 
589,597

 
225,981

Income (loss) before income taxes

($799,661
)
 

$1,549,854

 

$956,553

Computed at statutory rate (35%)

($279,881
)
 

$542,449

 

$334,794

Increases (reductions) in tax resulting from:
 

 
 

 
 

State income taxes net of federal income tax effect
29,944

 
44,708

 
13,599

Regulatory differences - utility plant items
32,089

 
39,321

 
32,324

Equity component of AFUDC
(18,191
)
 
(21,108
)
 
(22,356
)
Amortization of investment tax credits
(11,136
)
 
(12,211
)
 
(13,535
)
Flow-through / permanent differences
(7,872
)
 
(18,003
)
 
(301
)
Net-of-tax regulatory liability

 

 
(2,899
)
New York tax law change (a)

 
(21,500
)
 

Louisiana business combination
(333,655
)
 

 

Termination of business reorganization

 

 
(27,192
)
Provision for uncertain tax positions (b)
(56,683
)
 
32,573

 
(59,249
)
Valuation allowance

 

 
(31,573
)
Other - net
2,458

 
3,368

 
2,369

Total income taxes as reported

($642,927
)
 

$589,597

 

$225,981

Effective Income Tax Rate
80.4
%
 
38.0
%
 
23.6
%


(a)
In March 2014, New York enacted legislation that substantially modifies various aspects of New York tax law. The most significant effect of the legislation for Entergy is the adoption of full water’s-edge unitary combined reporting, meaning that all of Entergy’s domestic entities will be included in New York’s combined filing group. The effect of the tax law change resulted in a deferred state income tax reduction of approximately $21.5 million as shown in the table above.
(b)
See “Income Tax Audits - 2008-2009 IRS Audit” below for discussion of the most significant items for 2015 and 2013.

Total income taxes for the Registrant Subsidiaries differ from the amounts computed by applying the statutory income tax rate to income before taxes.  The reasons for the differences for the years 2015, 2014, and 2013 are:
2015
 
Entergy
Arkansas
 
Entergy
Louisiana
 
Entergy
Mississippi
 
Entergy
New Orleans
 
Entergy
Texas
 
System
Energy
 
 
(In Thousands)
Net income
 

$74,272

 

$446,639

 

$92,708

 

$44,925

 

$69,625

 

$111,318

Income taxes
 
40,541

 
178,671

 
61,872

 
25,190

 
37,250

 
53,077

Pretax income
 

$114,813

 

$625,310

 

$154,580

 

$70,115

 

$106,875

 

$164,395

Computed at statutory rate (35%)
 

$40,185

 

$218,859

 

$54,103

 

$24,540

 

$37,406

 

$57,538

Increases (reductions) in tax resulting from:
 
 
 
 

 
 

 
 

 
 

 
 

State income taxes net of federal income tax effect
 
6,643

 
23,650

 
5,219

 
2,887

 
1,621

 
6,403

Regulatory differences - utility plant items
 
7,299

 
3,013

 
2,383

 
2,201

 
3,703

 
12,167

Equity component of AFUDC
 
(4,979
)
 
(5,420
)
 
(1,083
)
 
(451
)
 
(1,987
)
 
(2,973
)
Amortization of investment tax credits
 
(1,201
)
 
(5,252
)
 
(160
)
 
(111
)
 
(900
)
 
(3,476
)
Flow-through / permanent differences
 
(4,062
)
 
2,460

 
431

 
(4,539
)
 
530

 
618

Non-taxable dividend income
 

 
(44,658
)
 

 

 

 

Provision for uncertain tax positions (a)
 
(3,978
)
 
(15,377
)
 
756

 
525

 
(3,365
)
 
(17,313
)
Other - net
 
634

 
1,396

 
223

 
138

 
242

 
113

Total income taxes
 

$40,541

 

$178,671

 

$61,872

 

$25,190

 

$37,250

 

$53,077

Effective Income Tax Rate
 
35.3
%
 
28.6
%
 
40.0
%
 
35.9
%
 
34.9
%
 
32.3
%


(a)
See “Income Tax Audits - 2008-2009 IRS Audit” below for discussion of the most significant items for Entergy Louisiana and System Energy.

2014
 
Entergy
Arkansas
 
Entergy
Louisiana
 
Entergy
Mississippi
 
Entergy
New Orleans
 
Entergy
Texas
 
System
Energy
 
 
(In Thousands)
Net income
 

$121,392

 

$446,022

 

$74,821

 

$31,030

 

$74,804

 

$96,334

Income taxes
 
83,629

 
185,052

 
55,710

 
13,450

 
49,644

 
83,310

Pretax income
 

$205,021

 

$631,074

 

$130,531

 

$44,480

 

$124,448

 

$179,644

Computed at statutory rate (35%)
 

$71,757

 

$220,876

 

$45,686

 

$15,568

 

$43,557

 

$62,875

Increases (reductions) in tax resulting from:
 
 

 
 

 
 

 
 

 
 

 
 

State income taxes net of federal income tax effect
 
9,591

 
11,666

 
5,180

 
1,562

 
3,221

 
6,877

Regulatory differences - utility plant items
 
8,653

 
7,487

 
4,448

 
777

 
4,165

 
13,791

Equity component of AFUDC
 
(2,533
)
 
(14,612
)
 
(833
)
 
(320
)
 
(1,035
)
 
(1,774
)
Amortization of investment tax credits
 
(1,251
)
 
(5,594
)
 
(260
)
 
(218
)
 
(1,412
)
 
(3,476
)
Flow-through / permanent differences
 
(5,082
)
 
(225
)
 
555

 
(4,458
)
 
393

 
(327
)
Non-taxable dividend income
 

 
(41,255
)
 

 

 

 

Provision for uncertain tax positions
 
1,881

 
5,336

 
718

 
405

 
522

 
5,235

Other - net
 
613

 
1,373

 
216

 
134

 
233

 
109

Total income taxes
 

$83,629

 

$185,052

 

$55,710

 

$13,450

 

$49,644

 

$83,310

Effective Income Tax Rate
 
40.8
%
 
29.3
%
 
42.7
%
 
30.2
%
 
39.9
%
 
46.4
%


2013
 
Entergy
Arkansas
 
Entergy
Louisiana
 
Entergy
Mississippi
 
Entergy
New Orleans
 
Entergy
Texas
 
System
Energy
 
 
(In Thousands)
Net income
 

$161,948

 

$414,126

 

$82,159

 

$12,608

 

$57,881

 

$113,664

Income taxes
 
91,787

 
138,696

 
49,757

 
2,277

 
30,108

 
68,853

Pretax income
 

$253,735

 

$552,822

 

$131,916

 

$14,885

 

$87,989

 

$182,517

Computed at statutory rate (35%)
 

$88,807

 

$193,488

 

$46,171

 

$5,210

 

$30,796

 

$63,881

Increases (reductions) in tax resulting from:
 
 

 
 

 
 

 
 

 
 

 
 

State income taxes net of federal income tax effect
 
10,954

 
19,084

 
4,564

 
1,116

 
(897
)
 
5,900

Regulatory differences - utility plant items
 
7,938

 
7,005

 
2,603

 
453

 
3,256

 
11,070

Equity component of AFUDC
 
(3,820
)
 
(13,100
)
 
(764
)
 
(322
)
 
(1,626
)
 
(2,724
)
Amortization of investment tax credits
 
(1,989
)
 
(5,864
)
 
(260
)
 
(216
)
 
(1,596
)
 
(3,476
)
Flow-through / permanent differences
 
2,540

 
3,646

 
1,702

 
(4,402
)
 
2,467

 
(491
)
Net-of-tax regulatory liability
 

 
(2,899
)
 

 

 

 

Termination of business organization
 
(6,753
)
 
(7,453
)
 
(4,177
)
 
(501
)
 
(3,542
)
 
(13
)
Non-taxable dividend income
 

 
(36,953
)
 

 

 

 

Provision for uncertain tax positions (a)
 
(6,527
)
 
(18,645
)
 
(326
)
 
795

 
1,027

 
(5,353
)
Other - net
 
637

 
387

 
244

 
144

 
223

 
59

Total income taxes
 

$91,787

 

$138,696

 

$49,757

 

$2,277

 

$30,108

 

$68,853

Effective Income Tax Rate
 
36.2
%
 
25.1
%
 
37.7
%
 
15.3
%
 
34.2
%
 
37.7
%


(a)
See “Income Tax Audits - 2008-2009 IRS Audit” below for discussion of the most significant items for Entergy Louisiana and System Energy.

Significant components of accumulated deferred income taxes and taxes accrued for Entergy Corporation and Subsidiaries as of December 31, 2015 and 2014 are as follows:
 
 
2015
 
2014
 
(In Thousands)
Deferred tax liabilities:
 
 
 
Plant basis differences - net

($6,804,225
)
 

($8,128,096
)
Regulatory assets
(646,392
)
 
(922,161
)
Nuclear decommissioning trusts
(1,254,463
)
 
(1,248,737
)
Pension, net funding
(365,111
)
 
(324,881
)
Combined unitary state taxes
(45,078
)
 
(162,340
)
Power purchase agreements

 
(110,889
)
Other
(315,844
)
 
(500,424
)
Total
(9,431,113
)
 
(11,397,528
)
Deferred tax assets:
 

 
 

Nuclear decommissioning liabilities
828,983

 
874,493

Regulatory liabilities
284,432

 
458,230

Pension and other post-employment benefits
525,524

 
586,455

Sale and leaseback
139,720

 
153,308

Compensation
69,432

 
74,692

Accumulated deferred investment tax credit
95,248

 
100,442

Provision for allowances and contingencies
188,282

 
160,551

Power purchase agreements
38,401

 

Net operating loss carryforwards
360,188

 
457,758

Capital losses and miscellaneous tax credits
11,075

 
12,146

Valuation allowance
(91,532
)
 
(27,387
)
Other
68,204

 
58,334

Total
2,517,957

 
2,909,022

Non-current accrued taxes (including unrecognized tax benefits)
(1,338,806
)
 
(606,560
)
Accumulated deferred income taxes and taxes accrued

($8,251,962
)
 

($9,095,066
)


Entergy’s estimated tax attributes carryovers and their expiration dates as of December 31, 2015 are as follows:
Carryover Description
 
Carryover Amount
 
Year(s) of expiration
 
 
 
 
 
Federal net operating losses
 
$3.6 billion
 
2023-2035
State net operating losses
 
$5.2 billion
 
2016-2035
Miscellaneous federal and state credits
 
$77.9 million
 
2016-2035


As a result of the accounting for uncertain tax positions, the amount of the deferred tax assets reflected in the financial statements is less than the amount of the tax effect of the federal and state net operating loss carryovers, tax credit carryovers, and other tax attributes reflected on income tax returns. Because it is more likely than not that the benefit from certain state net operating loss carryovers will not be utilized, valuation allowances of $46 million as of December 31, 2015 and $21 million as of December 31, 2014 have been provided on the deferred tax assets relating to these state net operating loss carryovers. Additionally, valuation allowances totaling $45.5 million as of December 31, 2015 have been provided on deferred tax assets related to state jurisdictions in which Entergy does not currently expect to be able to utilize separate company tax return losses, preventing realization of such deferred tax assets.
Significant components of accumulated deferred income taxes and taxes accrued for the Registrant Subsidiaries as of December 31, 2015 and 2014 are as follows:
2015
Entergy
Arkansas
 
Entergy
Louisiana
 
Entergy
Mississippi
 
Entergy
New Orleans
 
Entergy
Texas
 
System
Energy
 
(In Thousands)
Deferred tax liabilities:
 
 
 
 
 
 
 
 
 
 
 
Plant basis differences - net

($1,710,444
)
 

($2,041,968
)
 

($781,427
)
 

($167,294
)
 

($778,270
)
 

($611,745
)
Regulatory assets
(108,422
)
 
(254,316
)
 
(24,918
)
 
(39,451
)
 
(172,117
)
 
(46,990
)
Nuclear decommissioning trusts
(121,326
)
 
(99,980
)
 

 

 

 
(68,370
)
Pension, net funding
(107,073
)
 
(109,709
)
 
(30,901
)
 
(14,459
)
 
(28,001
)
 
(25,791
)
Deferred fuel
(7,647
)
 
(2,513
)
 
(684
)
 
(175
)
 
2,050

 
(18
)
Other
(38,683
)
 
(86,275
)
 
(5,625
)
 
(12,253
)
 
(10,109
)
 
(22,478
)
Total
(2,093,595
)
 
(2,594,761
)
 
(843,555
)
 
(233,632
)
 
(986,447
)
 
(775,392
)
Deferred tax assets:
 

 
 

 
 

 
 

 
 

 
 

Regulatory liabilities
18,369

 
215,154

 
7,787

 
20,888

 
7,307

 
14,927

Nuclear decommissioning liabilities
109,962

 
49,333

 

 

 

 
39,420

Pension and other post-employment benefits
(20,420
)
 
149,680

 
(6,628
)
 
(8,939
)
 
(16,703
)
 
(1,037
)
Sale and leaseback

 
37,236

 

 

 

 
102,484

Accumulated deferred investment tax credit
14,320

 
56,635

 
1,777

 
290

 
4,842

 
17,385

Provision for allowances and contingencies
1,024

 
123,007

 
18,735

 
33,843

 
7,266

 
134

Power purchase agreements
(1,279
)
 
13,840

 
1,901

 
13

 
575

 

Unbilled/deferred revenues
9,815

 
(32,365
)
 
7,154

 
2,126

 
10,851

 

Compensation
1,842

 
4,182

 
601

 
880

 
4,496

 

Net operating loss carryforwards

 
90,241

 

 

 

 

Other
128

 
21,982

 
1,995

 
316

 
1,672

 

Total
133,761

 
728,925

 
33,322

 
49,417

 
20,306

 
173,313

Non-current accrued taxes (including unrecognized tax benefits)
(22,978
)
 
(641,120
)
 
(402
)
 
(29,846
)
 
(40,693
)
 
(416,996
)
Accumulated deferred income taxes and taxes accrued

($1,982,812
)
 

($2,506,956
)
 

($810,635
)
 

($214,061
)
 

($1,006,834
)
 

($1,019,075
)
2014
 
Entergy
Arkansas
 
Entergy
Louisiana
 
Entergy
Mississippi
 
Entergy
New Orleans
 
Entergy
Texas
 
System
Energy
 
 
(In Thousands)
Deferred tax liabilities:
 
 
 
 
 
 
 
 
 
 
 
 
Plant basis differences - net
 

($1,657,503
)
 

($2,748,852
)
 

($753,576
)
 

($186,153
)
 

($771,135
)
 

($668,779
)
Regulatory assets
 
(198,662
)
 
(380,719
)
 
(30,114
)
 

 
(202,402
)
 
(110,087
)
Nuclear decommissioning trusts
 
(130,524
)
 
(106,162
)
 

 

 

 
(74,063
)
Pension, net funding
 
(93,355
)
 
(99,593
)
 
(27,861
)
 
(13,285
)
 
(25,616
)
 
(23,440
)
Deferred fuel
 
(82,050
)
 
(3,534
)
 
(5,303
)
 
(407
)
 
2,045

 
(120
)
Power purchase agreements
 
(17,073
)
 
(67,083
)
 
2,129

 
13

 
847

 

Other
 
(33,827
)
 
(84,282
)
 
(11,423
)
 
(11,500
)
 
(22,546
)
 
(19,802
)
Total
 
(2,212,994
)
 
(3,490,225
)
 
(826,148
)
 
(211,332
)
 
(1,018,807
)
 
(896,291
)
Deferred tax assets:
 
 

 
 

 
 

 
 

 
 

 
 

Regulatory liabilities
 
145,466

 
181,601

 
7,214

 
29,580

 
4,079

 
90,290

Nuclear decommissioning liabilities
 
(43,134
)
 
146,138

 

 

 

 
(62,571
)
Pension and other post-employment benefits
 
(17,534
)
 
158,661

 
(7,288
)
 
(7,504
)
 
(15,053
)
 
(1,413
)
Sale and leaseback
 

 
45,136

 

 

 

 
108,172

Accumulated deferred investment tax credit
 
14,791

 
58,863

 
2,436

 
332

 
5,158

 
18,862

Provision for allowances and contingencies
 
(7,149
)
 
125,805

 
19,590

 
10,986

 
8,017

 
133

Unbilled/deferred revenues
 
12,322

 
(25,016
)
 
12,956

 
3,395

 
11,573

 

Compensation
 
2,085

 
158

 
(846
)
 
475

 
4,155

 

Net operating loss carryforwards
 
105,063

 
241,803

 

 

 

 

Capital losses and miscellaneous tax credits
 

 

 
3,504

 

 

 

Other
 
258

 
15,508

 
5,887

 
2,891

 
3,850

 
2,000

Total
 
212,168

 
948,657

 
43,453

 
40,155

 
21,779

 
155,473

Non-current accrued taxes (including unrecognized tax benefits)
 
9,367

 
(412,508
)
 
(12,481
)
 
(19,502
)
 
(48,921
)
 
(81,528
)
Accumulated deferred income taxes and taxes accrued
 

($1,991,459
)
 

($2,954,076
)
 

($795,176
)
 

($190,679
)
 

($1,045,949
)
 

($822,346
)


The Registrant Subsidiaries’ estimated tax attributes carryovers and their expiration dates as of December 31, 2015 are as follows:
 
 
 
Entergy
Arkansas
 
 
Entergy
Louisiana
 
 
Entergy
Mississippi
 
Entergy
New Orleans
 
 
Entergy
Texas
 
 
System
Energy
 
 
 
 
 
 
 
 
 
 
 
 
 
Federal net operating losses
 
$7 million
 
$2.4 billion
 
 
 
 
$242 million
Year(s) of expiration
 
2030-2035
 
2035
 
N/A
 
N/A
 
N/A
 
2030-2035
 
 
 
 
 
 
 
 
 
 
 
 
 
State net operating losses
 
 
$2.5 billion
 
 
$6 million
 
 
$833 million
Year(s) of expiration
 
N/A
 
2035
 
N/A
 
2032
 
N/A
 
2035
 
 
 
 
 
 
 
 
 
 
 
 
 
Misc. federal credits
 
$1 million
 
 
$1 million
 
 
 
$1 million
Year(s) of expiration
 
2029-2033
 
N/A
 
2029-2034
 
N/A
 
N/A
 
2029-2033
 
 
 
 
 
 
 
 
 
 
 
 
 
State credits
 
 
 
 
 
$3.3 million
 
$6 million
Year(s) of expiration
 
N/A
 
N/A
 
N/A
 
N/A
 
2026
 
2017-2020


As a result of the accounting for uncertain tax positions, the amount of the deferred tax assets reflected in the financial statements is less than the amount of the tax effect of the federal and state net operating loss carryovers and tax credit carryovers.

Unrecognized tax benefits

Accounting standards establish a “more-likely-than-not” recognition threshold that must be met before a tax benefit can be recognized in the financial statements.  If a tax deduction is taken on a tax return, but does not meet the more-likely-than-not recognition threshold, an increase in income tax liability, above what is payable on the tax return, is required to be recorded.  A reconciliation of Entergy’s beginning and ending amount of unrecognized tax benefits is as follows:
 
2015
 
2014
 
2013
 
(In Thousands)
Gross balance at January 1

$4,736,785

 

$4,593,224

 

$4,170,403

Additions based on tax positions related to the current year
1,850,705

 
348,543

 
162,338

Additions for tax positions of prior years
59,815

 
11,637

 
410,108

Reductions for tax positions of prior years (a)
(3,966,535
)
 
(213,401
)
 
(103,360
)
Settlements
(68,227
)
 

 
(43,620
)
Lapse of statute of limitations
(958
)
 
(3,218
)
 
(2,645
)
Gross balance at December 31
2,611,585

 
4,736,785

 
4,593,224

Offsets to gross unrecognized tax benefits:
 

 
 

 
 

Credit and loss carryovers
(1,264,483
)
 
(4,295,643
)
 
(4,400,498
)
Unrecognized tax benefits net of unused tax attributes and payments (b)

$1,347,102

 

$441,142

 

$192,726



(a)
The primary reduction is related to the nuclear decommissioning costs treatment discussed in “Income Tax Audits - 2008-2009 IRS Audit” below.
(b)
Potential tax liability above what is payable on tax returns

The balances of unrecognized tax benefits include $955 million, $516 million, and $176 million as of December 31, 2015, 2014, and 2013, respectively, which, if recognized, would lower the effective income tax rates.  Because of the effect of deferred tax accounting, the remaining balances of unrecognized tax benefits of $1.657 billion, $4.221 billion, and $4.417 billion as of December 31, 2015, 2014, and 2013, respectively, if disallowed, would not affect the annual effective income tax rate but would accelerate the payment of cash to the taxing authority to an earlier period.

Entergy accrues interest expense, if any, related to unrecognized tax benefits in income tax expense.  Entergy’s December 31, 2015, 2014, and 2013 accrued balance for the possible payment of interest is approximately $27 million, $127 million, and $96.4 million, respectively.

A reconciliation of the Registrant Subsidiaries’ beginning and ending amount of unrecognized tax benefits for 2015, 2014, and 2013 is as follows:
2015
 
Entergy
Arkansas
 
Entergy
Louisiana
 
Entergy
Mississippi
 
Entergy
New Orleans
 
Entergy
Texas
 
System
Energy
 
 
(In Thousands)
Gross balance at January 1, 2015
 

$362,912

 

$1,205,929

 

$20,144

 

$53,763

 

$17,264

 

$258,242

Additions based on tax positions related to the current year (a)
 
2,196

 
1,367,058

 
566

 
472

 
657

 
472,304

Additions for tax positions of prior years
 
1,057

 
7,992

 
8,140

 
48

 
2,914

 
913

Reductions for tax positions of prior years
 
(340,720
)
 
(859,430
)
 

 
(386
)
 
(3,981
)
 
(253,141
)
Settlements
 

 
(30,888
)
 
(9,368
)
 

 
(3,392
)
 

Gross balance at December 31, 2015
 
25,445

 
1,690,661

 
19,482

 
53,897

 
13,462

 
478,318

Offsets to gross unrecognized tax benefits:
 
 

 
 

 
 

 
 

 
 

 
 

Loss carryovers
 
(3,613
)
 
(893,764
)
 
(1,016
)
 
(506
)
 
(276
)
 
(133,611
)
Unrecognized tax benefits net of unused tax attributes and payments
 

$21,832

 

$796,897

 

$18,466

 

$53,391

 

$13,186

 

$344,707



(a)
The primary addition for Entergy Louisiana and System Energy is related to the nuclear decommissioning costs treatment discussed in “Other Tax Matters” below.

2014
 
Entergy
Arkansas
 
Entergy
Louisiana
 
Entergy
Mississippi
 
Entergy
New Orleans
 
Entergy
Texas
 
System
Energy
 
 
(In Thousands)
Gross balance at January 1, 2014
 

$347,713

 

$1,076,680

 

$16,186

 

$51,679

 

$13,017

 

$265,185

Additions based on tax positions related to the current year
 
14,511

 
151,249

 
3,928

 
2,235

 
4,225

 
2,744

Additions for tax positions of prior years
 
1,767

 
6,924

 
319

 
37

 
303

 
566

Reductions for tax positions of prior years
 
(1,079
)
 
(28,924
)
 
(289
)
 
(188
)
 
(267
)
 
(10,253
)
Settlements
 

 

 

 

 
(14
)
 

Gross balance at December 31, 2014
 
362,912

 
1,205,929

 
20,144

 
53,763

 
17,264

 
258,242

Offsets to gross unrecognized tax benefits:
 
 

 
 

 
 

 
 

 
 

 
 

Loss carryovers
 
(361,043
)
 
(739,988
)
 
(6,992
)
 
(20,735
)
 
(241
)
 
(163,124
)
Unrecognized tax benefits net of unused tax attributes and payments
 

$1,869

 

$465,941

 

$13,152

 

$33,028

 

$17,023

 

$95,118


2013
 
Entergy
Arkansas
 
Entergy
Louisiana
 
Entergy
Mississippi
 
Entergy
New Orleans
 
Entergy
Texas
 
System
Energy
 
 
(In Thousands)
Gross balance at January 1, 2013
 

$344,669

 

$1,002,394

 

$16,841

 

$52,018

 

$13,954

 

$260,346

Additions based on tax positions related to the current year
 
6,427

 
17,887

 
957

 
583

 
2,170

 
4,170

Additions for tax positions of prior years
 
1,228

 
125,214

 
401

 
3,506

 
587

 
8,391

Reductions for tax positions of prior years
 
(3,943
)
 
(53,473
)
 
(1,941
)
 
(962
)
 
(4,186
)
 
(967
)
Settlements
 
(668
)
 
(15,342
)
 
(72
)
 
(3,466
)
 
492

 
(6,755
)
Gross balance at December 31, 2013
 
347,713

 
1,076,680

 
16,186

 
51,679

 
13,017

 
265,185

Offsets to gross unrecognized tax benefits:
 
 

 
 

 
 

 
 

 
 

 
 

Loss carryovers
 
(345,674
)
 
(747,756
)
 
(16,186
)
 
(22,078
)
 
(266
)
 
(225,286
)
Unrecognized tax benefits net of unused tax attributes and payments
 

$2,039

 

$328,924

 

$—

 

$29,601

 

$12,751

 

$39,899



The Registrant Subsidiaries’ balances of unrecognized tax benefits included amounts which, if recognized, would have reduced income tax expense as follows:
 
December 31,
 
2015
 
2014
 
2013
 
(In Millions)
Entergy Arkansas

$4.5

 

$2.6

 

$0.6

Entergy Louisiana

$692.7

 

$267.3

 

$131.9

Entergy Mississippi

$8.1

 

$3.9

 

$3.9

Entergy New Orleans

$50.7

 

$50.7

 

$—

Entergy Texas

$5.2

 

$10.5

 

$10.1

System Energy

$0.7

 

$3.7

 

$3.3



The Registrant Subsidiaries accrue interest and penalties related to unrecognized tax benefits in income tax expense.  Penalties have not been accrued.  Accrued balances for the possible payment of interest are as follows:
 
December 31,
 
2015
 
2014
 
2013
 
(In Millions)
Entergy Arkansas

$1.3

 

$17.0

 

$15.2

Entergy Louisiana

$9.3

 

$22.2

 

$18.0

Entergy Mississippi

$0.4

 

$2.8

 

$2.1

Entergy New Orleans

$1.8

 

$1.3

 

$0.9

Entergy Texas

$1.2

 

$1.0

 

$0.8

System Energy

$0.7

 

$23.8

 

$19.0



Income Tax Audits

Entergy and its subsidiaries file U.S. federal and various state and foreign income tax returns.  IRS examinations are complete for years before 2010. All state taxing authorities’ examinations are completed for years before 2009.

2006-2007 IRS Audit

In the first quarter 2015, the IRS finalized tax and interest computations from the 2006-2007 audit that resulted in a reversal of Entergy’s provision for uncertain tax positions related to accrued interest of approximately $20 million, including decreases of approximately $4 million for Entergy Arkansas, $11 million for Entergy Louisiana, and $1 million for System Energy.

2008-2009 IRS Audit

In the fourth quarter 2009, Entergy filed Applications for Change in Accounting Method (the “2009 CAM”) for tax purposes with the IRS for certain costs under Section 263A of the Internal Revenue Code.  In the Applications, Entergy proposed to treat the nuclear decommissioning liability associated with the operation of its nuclear power plants as a production cost properly includable in cost of goods sold.  The effect of the 2009 CAM was a $5.7 billion reduction in 2009 taxable income.  The 2009 CAM was adjusted to $9.3 billion in 2012.

In the fourth quarter 2012 the IRS disallowed the reduction to 2009 taxable income related to the 2009 CAM.  In the third quarter 2013, the Internal Revenue Service issued its RAR for the tax years 2008-2009. As a result of the issuance of this RAR, Entergy and the IRS resolved all of the 2008-2009 issues described above except for the 2009 CAM. Entergy disagreed with the IRS’s disallowance of the 2009 CAM and filed a protest with the IRS Appeals Division in October 2013.

In August 2015, Entergy and the IRS agreed on the treatment of the 2009 position regarding nuclear decommissioning liabilities from the 2008-2009 audit. The agreement provides that Entergy is entitled to deduct approximately $118 million of the $9.3 billion claimed in 2009. The agreement effectively settled all matters pertaining to the 2009 tax year and increased Entergy’s 2009 federal income tax liability by $2.4 million.

2010-2011 IRS Audit

The IRS examination of the 2010 and 2011 years is ongoing and the audit field work is expected to be completed by the end of the first quarter of 2016. The IRS has not issued any significant notices of proposed adjustments other than for the decommissioning liability position discussed above. The Revenue Agent’s Report is expected to be received shortly after the completion of field work.

Other Tax Matters

Entergy regularly negotiates with the IRS to achieve settlements.  The resolution of audit issues could result in significant changes to the amounts of unrecognized tax benefits in the next twelve months.

In September 2013 the U.S. Treasury Department and the IRS issued final regulations that provide guidance on the deductibility and capitalization of costs incurred associated with tangible property. Entergy and the Registrant Subsidiaries filed with the IRS an automatic application for change in accounting method which is in compliance with the final regulations and the safe harbor provisions of the relevant IRS Revenue Procedures. Entergy estimates that the effect of this accounting method change will result in a net increase to Entergy’s taxable income of approximately $585 million, which will be recognized generally over a four year period beginning with the tax year ended 2014. The adoption of the final regulations and safe harbor method results in approximate changes in the Registrant Subsidiaries taxable income as follows: an increase of $177 million for Entergy Arkansas, an increase of $78 million for Entergy Louisiana, an increase of $26 million for Entergy Mississippi, an increase of $183 million for Entergy Texas, a decrease of $2 million for Entergy New Orleans, and an increase of $22 million for System Energy.

In October 2015 two of Entergy’s Louisiana utilities, Entergy Gulf States Louisiana and Entergy Louisiana, combined their businesses into a legal entity which is identified as Entergy Louisiana herein. Entergy Louisiana maintained a carryover tax basis in the assets received. Additionally, the tax consequences provided for an increase in tax basis as well. To the extent that this increase in tax basis will provide additional tax depreciation, Entergy recorded a deferred tax asset and current tax expense resulting in a net increase in tax basis of approximately $334 million and Entergy Louisiana obtained a corresponding deferred tax asset. Consistent with the terms of an agreement with the LPSC, electric customers of Entergy Louisiana will realize customer credits associated with the business combination. Accordingly, in October 2015, Entergy recorded a regulatory liability of $107 million ($66 million net-of-tax) which partially offsets the effect of the aforementioned deferred tax asset. The deferred tax asset and the regulatory liability, net-of-tax, increased Entergy Louisiana’s member’s equity by $268 million. See Note 2 to the financial statements for further discussion of the business combination.

In the fourth quarter 2015, System Energy and Entergy Louisiana adopted a new method of accounting for income tax purposes in which the companies’ nuclear decommissioning costs will be treated as production costs of electricity includable in cost of goods sold. The new method results in a reduction of taxable income of $1.2 billion for System Energy and $2.2 billion for Entergy Louisiana.

The Protecting Americans from Tax Hikes Act of 2015 was enacted in December 2015. The most significant provisions affecting Entergy and the Registrant Subsidiaries were a five-year extension of bonus depreciation and permanent extension of the research and experimentation tax credit. The effect of the bonus depreciation extension on 2015 increased Entergy’s tax net operating loss.
System Energy [Member]  
Income Taxes
INCOME TAXES (Entergy Corporation, Entergy Arkansas, Entergy Louisiana, Entergy Mississippi, Entergy New Orleans, Entergy Texas, and System Energy)

Income taxes for 2015, 2014, and 2013 for Entergy Corporation and Subsidiaries consist of the following:
 
2015
 
2014
 
2013
 
(In Thousands)
Current:
 
 
 
 
 
Federal

$77,166

 

$90,061

 

$88,291

Foreign
97

 
90

 
101

State
157,829

 
(12,637
)
 
20,584

Total
235,092

 
77,514

 
108,976

Deferred and non-current - net
(864,799
)
 
528,326

 
126,935

Investment tax credit adjustments - net
(13,220
)
 
(16,243
)
 
(9,930
)
Income taxes

($642,927
)
 

$589,597

 

$225,981



Income taxes for 2015, 2014, and 2013 for Entergy’s Registrant Subsidiaries consist of the following:
2015
 
Entergy
Arkansas
 
Entergy
Louisiana
 
Entergy
Mississippi
 
Entergy
New Orleans
 
Entergy
Texas
 
System
Energy
 
 
(In Thousands)
Current:
 
 
 
 
 
 
 
 
 
 
 
 
Federal
 

$66,966

 

$101,382

 

$25,628

 

($9,346
)
 

$53,313

 

($63,302
)
State
 
6,265

 
35,406

 
6,832

 
1,784

 
2,450

 
26,755

Total
 
73,231

 
136,788

 
32,460

 
(7,562
)
 
55,763

 
(36,547
)
Deferred and non-current - net
 
(31,463
)
 
47,220

 
31,149

 
32,890

 
(17,599
)
 
93,491

Investment tax credit adjustments - net
 
(1,227
)
 
(5,337
)
 
(1,737
)
 
(138
)
 
(914
)
 
(3,867
)
Income taxes
 

$40,541

 

$178,671

 

$61,872

 

$25,190

 

$37,250

 

$53,077


2014
 
Entergy
Arkansas
 
Entergy
Louisiana
 
Entergy
Mississippi
 
Entergy
New Orleans
 
Entergy
Texas
 
System
Energy
 
 
(In Thousands)
Current:
 
 
 
 
 
 
 
 
 
 
 
 
Federal
 

($34,258
)
 

($44,909
)
 

$8,103

 

($1,428
)
 

$48,610

 

$19,908

State
 
(678
)
 
(1,191
)
 
7,474

 
510

 
4,877

 
15,379

Total
 
(34,936
)
 
(46,100
)
 
15,577

 
(918
)
 
53,487

 
35,287

Deferred and non-current - net
 
119,841

 
236,794

 
42,305

 
14,592

 
(2,418
)
 
53,501

Investment tax credit adjustments - net
 
(1,276
)
 
(5,642
)
 
(2,172
)
 
(224
)
 
(1,425
)
 
(5,478
)
Income taxes
 

$83,629

 

$185,052

 

$55,710

 

$13,450

 

$49,644

 

$83,310


2013
 
Entergy
Arkansas
 
Entergy
Louisiana
 
Entergy
Mississippi
 
Entergy
New Orleans
 
Entergy
Texas
 
System
Energy
 
 
(In Thousands)
Current:
 
 
 
 
 
 
 
 
 
 
 
 
Federal
 

($13,574
)
 

($18,797
)
 

$2,498

 

$14,823

 

$37,199

 

($6,199
)
State
 
6,122

 
(15,631
)
 
4,849

 
(1,267
)
 
(843
)
 
15,845

Total
 
(7,452
)
 
(34,428
)
 
7,347

 
13,556

 
36,356

 
9,646

Deferred and non-current - net
 
101,253

 
179,036

 
41,150

 
(11,033
)
 
(4,639
)
 
60,614

Investment tax credit adjustments - net
 
(2,014
)
 
(5,912
)
 
1,260

 
(246
)
 
(1,609
)
 
(1,407
)
Income taxes
 

$91,787

 

$138,696

 

$49,757

 

$2,277

 

$30,108

 

$68,853



Total income taxes for Entergy Corporation and Subsidiaries differ from the amounts computed by applying the statutory income tax rate to income before income taxes.  The reasons for the differences for the years 2015, 2014, and 2013 are:
 
2015
 
2014
 
2013
 
(In Thousands)
Net income (loss) attributable to Entergy Corporation

($176,562
)
 

$940,721

 

$711,902

Preferred dividend requirements of subsidiaries
19,828

 
19,536

 
18,670

Consolidated net income (loss)
(156,734
)
 
960,257

 
730,572

Income taxes
(642,927
)
 
589,597

 
225,981

Income (loss) before income taxes

($799,661
)
 

$1,549,854

 

$956,553

Computed at statutory rate (35%)

($279,881
)
 

$542,449

 

$334,794

Increases (reductions) in tax resulting from:
 

 
 

 
 

State income taxes net of federal income tax effect
29,944

 
44,708

 
13,599

Regulatory differences - utility plant items
32,089

 
39,321

 
32,324

Equity component of AFUDC
(18,191
)
 
(21,108
)
 
(22,356
)
Amortization of investment tax credits
(11,136
)
 
(12,211
)
 
(13,535
)
Flow-through / permanent differences
(7,872
)
 
(18,003
)
 
(301
)
Net-of-tax regulatory liability

 

 
(2,899
)
New York tax law change (a)

 
(21,500
)
 

Louisiana business combination
(333,655
)
 

 

Termination of business reorganization

 

 
(27,192
)
Provision for uncertain tax positions (b)
(56,683
)
 
32,573

 
(59,249
)
Valuation allowance

 

 
(31,573
)
Other - net
2,458

 
3,368

 
2,369

Total income taxes as reported

($642,927
)
 

$589,597

 

$225,981

Effective Income Tax Rate
80.4
%
 
38.0
%
 
23.6
%


(a)
In March 2014, New York enacted legislation that substantially modifies various aspects of New York tax law. The most significant effect of the legislation for Entergy is the adoption of full water’s-edge unitary combined reporting, meaning that all of Entergy’s domestic entities will be included in New York’s combined filing group. The effect of the tax law change resulted in a deferred state income tax reduction of approximately $21.5 million as shown in the table above.
(b)
See “Income Tax Audits - 2008-2009 IRS Audit” below for discussion of the most significant items for 2015 and 2013.

Total income taxes for the Registrant Subsidiaries differ from the amounts computed by applying the statutory income tax rate to income before taxes.  The reasons for the differences for the years 2015, 2014, and 2013 are:
2015
 
Entergy
Arkansas
 
Entergy
Louisiana
 
Entergy
Mississippi
 
Entergy
New Orleans
 
Entergy
Texas
 
System
Energy
 
 
(In Thousands)
Net income
 

$74,272

 

$446,639

 

$92,708

 

$44,925

 

$69,625

 

$111,318

Income taxes
 
40,541

 
178,671

 
61,872

 
25,190

 
37,250

 
53,077

Pretax income
 

$114,813

 

$625,310

 

$154,580

 

$70,115

 

$106,875

 

$164,395

Computed at statutory rate (35%)
 

$40,185

 

$218,859

 

$54,103

 

$24,540

 

$37,406

 

$57,538

Increases (reductions) in tax resulting from:
 
 
 
 

 
 

 
 

 
 

 
 

State income taxes net of federal income tax effect
 
6,643

 
23,650

 
5,219

 
2,887

 
1,621

 
6,403

Regulatory differences - utility plant items
 
7,299

 
3,013

 
2,383

 
2,201

 
3,703

 
12,167

Equity component of AFUDC
 
(4,979
)
 
(5,420
)
 
(1,083
)
 
(451
)
 
(1,987
)
 
(2,973
)
Amortization of investment tax credits
 
(1,201
)
 
(5,252
)
 
(160
)
 
(111
)
 
(900
)
 
(3,476
)
Flow-through / permanent differences
 
(4,062
)
 
2,460

 
431

 
(4,539
)
 
530

 
618

Non-taxable dividend income
 

 
(44,658
)
 

 

 

 

Provision for uncertain tax positions (a)
 
(3,978
)
 
(15,377
)
 
756

 
525

 
(3,365
)
 
(17,313
)
Other - net
 
634

 
1,396

 
223

 
138

 
242

 
113

Total income taxes
 

$40,541

 

$178,671

 

$61,872

 

$25,190

 

$37,250

 

$53,077

Effective Income Tax Rate
 
35.3
%
 
28.6
%
 
40.0
%
 
35.9
%
 
34.9
%
 
32.3
%


(a)
See “Income Tax Audits - 2008-2009 IRS Audit” below for discussion of the most significant items for Entergy Louisiana and System Energy.

2014
 
Entergy
Arkansas
 
Entergy
Louisiana
 
Entergy
Mississippi
 
Entergy
New Orleans
 
Entergy
Texas
 
System
Energy
 
 
(In Thousands)
Net income
 

$121,392

 

$446,022

 

$74,821

 

$31,030

 

$74,804

 

$96,334

Income taxes
 
83,629

 
185,052

 
55,710

 
13,450

 
49,644

 
83,310

Pretax income
 

$205,021

 

$631,074

 

$130,531

 

$44,480

 

$124,448

 

$179,644

Computed at statutory rate (35%)
 

$71,757

 

$220,876

 

$45,686

 

$15,568

 

$43,557

 

$62,875

Increases (reductions) in tax resulting from:
 
 

 
 

 
 

 
 

 
 

 
 

State income taxes net of federal income tax effect
 
9,591

 
11,666

 
5,180

 
1,562

 
3,221

 
6,877

Regulatory differences - utility plant items
 
8,653

 
7,487

 
4,448

 
777

 
4,165

 
13,791

Equity component of AFUDC
 
(2,533
)
 
(14,612
)
 
(833
)
 
(320
)
 
(1,035
)
 
(1,774
)
Amortization of investment tax credits
 
(1,251
)
 
(5,594
)
 
(260
)
 
(218
)
 
(1,412
)
 
(3,476
)
Flow-through / permanent differences
 
(5,082
)
 
(225
)
 
555

 
(4,458
)
 
393

 
(327
)
Non-taxable dividend income
 

 
(41,255
)
 

 

 

 

Provision for uncertain tax positions
 
1,881

 
5,336

 
718

 
405

 
522

 
5,235

Other - net
 
613

 
1,373

 
216

 
134

 
233

 
109

Total income taxes
 

$83,629

 

$185,052

 

$55,710

 

$13,450

 

$49,644

 

$83,310

Effective Income Tax Rate
 
40.8
%
 
29.3
%
 
42.7
%
 
30.2
%
 
39.9
%
 
46.4
%


2013
 
Entergy
Arkansas
 
Entergy
Louisiana
 
Entergy
Mississippi
 
Entergy
New Orleans
 
Entergy
Texas
 
System
Energy
 
 
(In Thousands)
Net income
 

$161,948

 

$414,126

 

$82,159

 

$12,608

 

$57,881

 

$113,664

Income taxes
 
91,787

 
138,696

 
49,757

 
2,277

 
30,108

 
68,853

Pretax income
 

$253,735

 

$552,822

 

$131,916

 

$14,885

 

$87,989

 

$182,517

Computed at statutory rate (35%)
 

$88,807

 

$193,488

 

$46,171

 

$5,210

 

$30,796

 

$63,881

Increases (reductions) in tax resulting from:
 
 

 
 

 
 

 
 

 
 

 
 

State income taxes net of federal income tax effect
 
10,954

 
19,084

 
4,564

 
1,116

 
(897
)
 
5,900

Regulatory differences - utility plant items
 
7,938

 
7,005

 
2,603

 
453

 
3,256

 
11,070

Equity component of AFUDC
 
(3,820
)
 
(13,100
)
 
(764
)
 
(322
)
 
(1,626
)
 
(2,724
)
Amortization of investment tax credits
 
(1,989
)
 
(5,864
)
 
(260
)
 
(216
)
 
(1,596
)
 
(3,476
)
Flow-through / permanent differences
 
2,540

 
3,646

 
1,702

 
(4,402
)
 
2,467

 
(491
)
Net-of-tax regulatory liability
 

 
(2,899
)
 

 

 

 

Termination of business organization
 
(6,753
)
 
(7,453
)
 
(4,177
)
 
(501
)
 
(3,542
)
 
(13
)
Non-taxable dividend income
 

 
(36,953
)
 

 

 

 

Provision for uncertain tax positions (a)
 
(6,527
)
 
(18,645
)
 
(326
)
 
795

 
1,027

 
(5,353
)
Other - net
 
637

 
387

 
244

 
144

 
223

 
59

Total income taxes
 

$91,787

 

$138,696

 

$49,757

 

$2,277

 

$30,108

 

$68,853

Effective Income Tax Rate
 
36.2
%
 
25.1
%
 
37.7
%
 
15.3
%
 
34.2
%
 
37.7
%


(a)
See “Income Tax Audits - 2008-2009 IRS Audit” below for discussion of the most significant items for Entergy Louisiana and System Energy.

Significant components of accumulated deferred income taxes and taxes accrued for Entergy Corporation and Subsidiaries as of December 31, 2015 and 2014 are as follows:
 
 
2015
 
2014
 
(In Thousands)
Deferred tax liabilities:
 
 
 
Plant basis differences - net

($6,804,225
)
 

($8,128,096
)
Regulatory assets
(646,392
)
 
(922,161
)
Nuclear decommissioning trusts
(1,254,463
)
 
(1,248,737
)
Pension, net funding
(365,111
)
 
(324,881
)
Combined unitary state taxes
(45,078
)
 
(162,340
)
Power purchase agreements

 
(110,889
)
Other
(315,844
)
 
(500,424
)
Total
(9,431,113
)
 
(11,397,528
)
Deferred tax assets:
 

 
 

Nuclear decommissioning liabilities
828,983

 
874,493

Regulatory liabilities
284,432

 
458,230

Pension and other post-employment benefits
525,524

 
586,455

Sale and leaseback
139,720

 
153,308

Compensation
69,432

 
74,692

Accumulated deferred investment tax credit
95,248

 
100,442

Provision for allowances and contingencies
188,282

 
160,551

Power purchase agreements
38,401

 

Net operating loss carryforwards
360,188

 
457,758

Capital losses and miscellaneous tax credits
11,075

 
12,146

Valuation allowance
(91,532
)
 
(27,387
)
Other
68,204

 
58,334

Total
2,517,957

 
2,909,022

Non-current accrued taxes (including unrecognized tax benefits)
(1,338,806
)
 
(606,560
)
Accumulated deferred income taxes and taxes accrued

($8,251,962
)
 

($9,095,066
)


Entergy’s estimated tax attributes carryovers and their expiration dates as of December 31, 2015 are as follows:
Carryover Description
 
Carryover Amount
 
Year(s) of expiration
 
 
 
 
 
Federal net operating losses
 
$3.6 billion
 
2023-2035
State net operating losses
 
$5.2 billion
 
2016-2035
Miscellaneous federal and state credits
 
$77.9 million
 
2016-2035


As a result of the accounting for uncertain tax positions, the amount of the deferred tax assets reflected in the financial statements is less than the amount of the tax effect of the federal and state net operating loss carryovers, tax credit carryovers, and other tax attributes reflected on income tax returns. Because it is more likely than not that the benefit from certain state net operating loss carryovers will not be utilized, valuation allowances of $46 million as of December 31, 2015 and $21 million as of December 31, 2014 have been provided on the deferred tax assets relating to these state net operating loss carryovers. Additionally, valuation allowances totaling $45.5 million as of December 31, 2015 have been provided on deferred tax assets related to state jurisdictions in which Entergy does not currently expect to be able to utilize separate company tax return losses, preventing realization of such deferred tax assets.
Significant components of accumulated deferred income taxes and taxes accrued for the Registrant Subsidiaries as of December 31, 2015 and 2014 are as follows:
2015
Entergy
Arkansas
 
Entergy
Louisiana
 
Entergy
Mississippi
 
Entergy
New Orleans
 
Entergy
Texas
 
System
Energy
 
(In Thousands)
Deferred tax liabilities:
 
 
 
 
 
 
 
 
 
 
 
Plant basis differences - net

($1,710,444
)
 

($2,041,968
)
 

($781,427
)
 

($167,294
)
 

($778,270
)
 

($611,745
)
Regulatory assets
(108,422
)
 
(254,316
)
 
(24,918
)
 
(39,451
)
 
(172,117
)
 
(46,990
)
Nuclear decommissioning trusts
(121,326
)
 
(99,980
)
 

 

 

 
(68,370
)
Pension, net funding
(107,073
)
 
(109,709
)
 
(30,901
)
 
(14,459
)
 
(28,001
)
 
(25,791
)
Deferred fuel
(7,647
)
 
(2,513
)
 
(684
)
 
(175
)
 
2,050

 
(18
)
Other
(38,683
)
 
(86,275
)
 
(5,625
)
 
(12,253
)
 
(10,109
)
 
(22,478
)
Total
(2,093,595
)
 
(2,594,761
)
 
(843,555
)
 
(233,632
)
 
(986,447
)
 
(775,392
)
Deferred tax assets:
 

 
 

 
 

 
 

 
 

 
 

Regulatory liabilities
18,369

 
215,154

 
7,787

 
20,888

 
7,307

 
14,927

Nuclear decommissioning liabilities
109,962

 
49,333

 

 

 

 
39,420

Pension and other post-employment benefits
(20,420
)
 
149,680

 
(6,628
)
 
(8,939
)
 
(16,703
)
 
(1,037
)
Sale and leaseback

 
37,236

 

 

 

 
102,484

Accumulated deferred investment tax credit
14,320

 
56,635

 
1,777

 
290

 
4,842

 
17,385

Provision for allowances and contingencies
1,024

 
123,007

 
18,735

 
33,843

 
7,266

 
134

Power purchase agreements
(1,279
)
 
13,840

 
1,901

 
13

 
575

 

Unbilled/deferred revenues
9,815

 
(32,365
)
 
7,154

 
2,126

 
10,851

 

Compensation
1,842

 
4,182

 
601

 
880

 
4,496

 

Net operating loss carryforwards

 
90,241

 

 

 

 

Other
128

 
21,982

 
1,995

 
316

 
1,672

 

Total
133,761

 
728,925

 
33,322

 
49,417

 
20,306

 
173,313

Non-current accrued taxes (including unrecognized tax benefits)
(22,978
)
 
(641,120
)
 
(402
)
 
(29,846
)
 
(40,693
)
 
(416,996
)
Accumulated deferred income taxes and taxes accrued

($1,982,812
)
 

($2,506,956
)
 

($810,635
)
 

($214,061
)
 

($1,006,834
)
 

($1,019,075
)
2014
 
Entergy
Arkansas
 
Entergy
Louisiana
 
Entergy
Mississippi
 
Entergy
New Orleans
 
Entergy
Texas
 
System
Energy
 
 
(In Thousands)
Deferred tax liabilities:
 
 
 
 
 
 
 
 
 
 
 
 
Plant basis differences - net
 

($1,657,503
)
 

($2,748,852
)
 

($753,576
)
 

($186,153
)
 

($771,135
)
 

($668,779
)
Regulatory assets
 
(198,662
)
 
(380,719
)
 
(30,114
)
 

 
(202,402
)
 
(110,087
)
Nuclear decommissioning trusts
 
(130,524
)
 
(106,162
)
 

 

 

 
(74,063
)
Pension, net funding
 
(93,355
)
 
(99,593
)
 
(27,861
)
 
(13,285
)
 
(25,616
)
 
(23,440
)
Deferred fuel
 
(82,050
)
 
(3,534
)
 
(5,303
)
 
(407
)
 
2,045

 
(120
)
Power purchase agreements
 
(17,073
)
 
(67,083
)
 
2,129

 
13

 
847

 

Other
 
(33,827
)
 
(84,282
)
 
(11,423
)
 
(11,500
)
 
(22,546
)
 
(19,802
)
Total
 
(2,212,994
)
 
(3,490,225
)
 
(826,148
)
 
(211,332
)
 
(1,018,807
)
 
(896,291
)
Deferred tax assets:
 
 

 
 

 
 

 
 

 
 

 
 

Regulatory liabilities
 
145,466

 
181,601

 
7,214

 
29,580

 
4,079

 
90,290

Nuclear decommissioning liabilities
 
(43,134
)
 
146,138

 

 

 

 
(62,571
)
Pension and other post-employment benefits
 
(17,534
)
 
158,661

 
(7,288
)
 
(7,504
)
 
(15,053
)
 
(1,413
)
Sale and leaseback
 

 
45,136

 

 

 

 
108,172

Accumulated deferred investment tax credit
 
14,791

 
58,863

 
2,436

 
332

 
5,158

 
18,862

Provision for allowances and contingencies
 
(7,149
)
 
125,805

 
19,590

 
10,986

 
8,017

 
133

Unbilled/deferred revenues
 
12,322

 
(25,016
)
 
12,956

 
3,395

 
11,573

 

Compensation
 
2,085

 
158

 
(846
)
 
475

 
4,155

 

Net operating loss carryforwards
 
105,063

 
241,803

 

 

 

 

Capital losses and miscellaneous tax credits
 

 

 
3,504

 

 

 

Other
 
258

 
15,508

 
5,887

 
2,891

 
3,850

 
2,000

Total
 
212,168

 
948,657

 
43,453

 
40,155

 
21,779

 
155,473

Non-current accrued taxes (including unrecognized tax benefits)
 
9,367

 
(412,508
)
 
(12,481
)
 
(19,502
)
 
(48,921
)
 
(81,528
)
Accumulated deferred income taxes and taxes accrued
 

($1,991,459
)
 

($2,954,076
)
 

($795,176
)
 

($190,679
)
 

($1,045,949
)
 

($822,346
)


The Registrant Subsidiaries’ estimated tax attributes carryovers and their expiration dates as of December 31, 2015 are as follows:
 
 
 
Entergy
Arkansas
 
 
Entergy
Louisiana
 
 
Entergy
Mississippi
 
Entergy
New Orleans
 
 
Entergy
Texas
 
 
System
Energy
 
 
 
 
 
 
 
 
 
 
 
 
 
Federal net operating losses
 
$7 million
 
$2.4 billion
 
 
 
 
$242 million
Year(s) of expiration
 
2030-2035
 
2035
 
N/A
 
N/A
 
N/A
 
2030-2035
 
 
 
 
 
 
 
 
 
 
 
 
 
State net operating losses
 
 
$2.5 billion
 
 
$6 million
 
 
$833 million
Year(s) of expiration
 
N/A
 
2035
 
N/A
 
2032
 
N/A
 
2035
 
 
 
 
 
 
 
 
 
 
 
 
 
Misc. federal credits
 
$1 million
 
 
$1 million
 
 
 
$1 million
Year(s) of expiration
 
2029-2033
 
N/A
 
2029-2034
 
N/A
 
N/A
 
2029-2033
 
 
 
 
 
 
 
 
 
 
 
 
 
State credits
 
 
 
 
 
$3.3 million
 
$6 million
Year(s) of expiration
 
N/A
 
N/A
 
N/A
 
N/A
 
2026
 
2017-2020


As a result of the accounting for uncertain tax positions, the amount of the deferred tax assets reflected in the financial statements is less than the amount of the tax effect of the federal and state net operating loss carryovers and tax credit carryovers.

Unrecognized tax benefits

Accounting standards establish a “more-likely-than-not” recognition threshold that must be met before a tax benefit can be recognized in the financial statements.  If a tax deduction is taken on a tax return, but does not meet the more-likely-than-not recognition threshold, an increase in income tax liability, above what is payable on the tax return, is required to be recorded.  A reconciliation of Entergy’s beginning and ending amount of unrecognized tax benefits is as follows:
 
2015
 
2014
 
2013
 
(In Thousands)
Gross balance at January 1

$4,736,785

 

$4,593,224

 

$4,170,403

Additions based on tax positions related to the current year
1,850,705

 
348,543

 
162,338

Additions for tax positions of prior years
59,815

 
11,637

 
410,108

Reductions for tax positions of prior years (a)
(3,966,535
)
 
(213,401
)
 
(103,360
)
Settlements
(68,227
)
 

 
(43,620
)
Lapse of statute of limitations
(958
)
 
(3,218
)
 
(2,645
)
Gross balance at December 31
2,611,585

 
4,736,785

 
4,593,224

Offsets to gross unrecognized tax benefits:
 

 
 

 
 

Credit and loss carryovers
(1,264,483
)
 
(4,295,643
)
 
(4,400,498
)
Unrecognized tax benefits net of unused tax attributes and payments (b)

$1,347,102

 

$441,142

 

$192,726



(a)
The primary reduction is related to the nuclear decommissioning costs treatment discussed in “Income Tax Audits - 2008-2009 IRS Audit” below.
(b)
Potential tax liability above what is payable on tax returns

The balances of unrecognized tax benefits include $955 million, $516 million, and $176 million as of December 31, 2015, 2014, and 2013, respectively, which, if recognized, would lower the effective income tax rates.  Because of the effect of deferred tax accounting, the remaining balances of unrecognized tax benefits of $1.657 billion, $4.221 billion, and $4.417 billion as of December 31, 2015, 2014, and 2013, respectively, if disallowed, would not affect the annual effective income tax rate but would accelerate the payment of cash to the taxing authority to an earlier period.

Entergy accrues interest expense, if any, related to unrecognized tax benefits in income tax expense.  Entergy’s December 31, 2015, 2014, and 2013 accrued balance for the possible payment of interest is approximately $27 million, $127 million, and $96.4 million, respectively.

A reconciliation of the Registrant Subsidiaries’ beginning and ending amount of unrecognized tax benefits for 2015, 2014, and 2013 is as follows:
2015
 
Entergy
Arkansas
 
Entergy
Louisiana
 
Entergy
Mississippi
 
Entergy
New Orleans
 
Entergy
Texas
 
System
Energy
 
 
(In Thousands)
Gross balance at January 1, 2015
 

$362,912

 

$1,205,929

 

$20,144

 

$53,763

 

$17,264

 

$258,242

Additions based on tax positions related to the current year (a)
 
2,196

 
1,367,058

 
566

 
472

 
657

 
472,304

Additions for tax positions of prior years
 
1,057

 
7,992

 
8,140

 
48

 
2,914

 
913

Reductions for tax positions of prior years
 
(340,720
)
 
(859,430
)
 

 
(386
)
 
(3,981
)
 
(253,141
)
Settlements
 

 
(30,888
)
 
(9,368
)
 

 
(3,392
)
 

Gross balance at December 31, 2015
 
25,445

 
1,690,661

 
19,482

 
53,897

 
13,462

 
478,318

Offsets to gross unrecognized tax benefits:
 
 

 
 

 
 

 
 

 
 

 
 

Loss carryovers
 
(3,613
)
 
(893,764
)
 
(1,016
)
 
(506
)
 
(276
)
 
(133,611
)
Unrecognized tax benefits net of unused tax attributes and payments
 

$21,832

 

$796,897

 

$18,466

 

$53,391

 

$13,186

 

$344,707



(a)
The primary addition for Entergy Louisiana and System Energy is related to the nuclear decommissioning costs treatment discussed in “Other Tax Matters” below.

2014
 
Entergy
Arkansas
 
Entergy
Louisiana
 
Entergy
Mississippi
 
Entergy
New Orleans
 
Entergy
Texas
 
System
Energy
 
 
(In Thousands)
Gross balance at January 1, 2014
 

$347,713

 

$1,076,680

 

$16,186

 

$51,679

 

$13,017

 

$265,185

Additions based on tax positions related to the current year
 
14,511

 
151,249

 
3,928

 
2,235

 
4,225

 
2,744

Additions for tax positions of prior years
 
1,767

 
6,924

 
319

 
37

 
303

 
566

Reductions for tax positions of prior years
 
(1,079
)
 
(28,924
)
 
(289
)
 
(188
)
 
(267
)
 
(10,253
)
Settlements
 

 

 

 

 
(14
)
 

Gross balance at December 31, 2014
 
362,912

 
1,205,929

 
20,144

 
53,763

 
17,264

 
258,242

Offsets to gross unrecognized tax benefits:
 
 

 
 

 
 

 
 

 
 

 
 

Loss carryovers
 
(361,043
)
 
(739,988
)
 
(6,992
)
 
(20,735
)
 
(241
)
 
(163,124
)
Unrecognized tax benefits net of unused tax attributes and payments
 

$1,869

 

$465,941

 

$13,152

 

$33,028

 

$17,023

 

$95,118


2013
 
Entergy
Arkansas
 
Entergy
Louisiana
 
Entergy
Mississippi
 
Entergy
New Orleans
 
Entergy
Texas
 
System
Energy
 
 
(In Thousands)
Gross balance at January 1, 2013
 

$344,669

 

$1,002,394

 

$16,841

 

$52,018

 

$13,954

 

$260,346

Additions based on tax positions related to the current year
 
6,427

 
17,887

 
957

 
583

 
2,170

 
4,170

Additions for tax positions of prior years
 
1,228

 
125,214

 
401

 
3,506

 
587

 
8,391

Reductions for tax positions of prior years
 
(3,943
)
 
(53,473
)
 
(1,941
)
 
(962
)
 
(4,186
)
 
(967
)
Settlements
 
(668
)
 
(15,342
)
 
(72
)
 
(3,466
)
 
492

 
(6,755
)
Gross balance at December 31, 2013
 
347,713

 
1,076,680

 
16,186

 
51,679

 
13,017

 
265,185

Offsets to gross unrecognized tax benefits:
 
 

 
 

 
 

 
 

 
 

 
 

Loss carryovers
 
(345,674
)
 
(747,756
)
 
(16,186
)
 
(22,078
)
 
(266
)
 
(225,286
)
Unrecognized tax benefits net of unused tax attributes and payments
 

$2,039

 

$328,924

 

$—

 

$29,601

 

$12,751

 

$39,899



The Registrant Subsidiaries’ balances of unrecognized tax benefits included amounts which, if recognized, would have reduced income tax expense as follows:
 
December 31,
 
2015
 
2014
 
2013
 
(In Millions)
Entergy Arkansas

$4.5

 

$2.6

 

$0.6

Entergy Louisiana

$692.7

 

$267.3

 

$131.9

Entergy Mississippi

$8.1

 

$3.9

 

$3.9

Entergy New Orleans

$50.7

 

$50.7

 

$—

Entergy Texas

$5.2

 

$10.5

 

$10.1

System Energy

$0.7

 

$3.7

 

$3.3



The Registrant Subsidiaries accrue interest and penalties related to unrecognized tax benefits in income tax expense.  Penalties have not been accrued.  Accrued balances for the possible payment of interest are as follows:
 
December 31,
 
2015
 
2014
 
2013
 
(In Millions)
Entergy Arkansas

$1.3

 

$17.0

 

$15.2

Entergy Louisiana

$9.3

 

$22.2

 

$18.0

Entergy Mississippi

$0.4

 

$2.8

 

$2.1

Entergy New Orleans

$1.8

 

$1.3

 

$0.9

Entergy Texas

$1.2

 

$1.0

 

$0.8

System Energy

$0.7

 

$23.8

 

$19.0



Income Tax Audits

Entergy and its subsidiaries file U.S. federal and various state and foreign income tax returns.  IRS examinations are complete for years before 2010. All state taxing authorities’ examinations are completed for years before 2009.

2006-2007 IRS Audit

In the first quarter 2015, the IRS finalized tax and interest computations from the 2006-2007 audit that resulted in a reversal of Entergy’s provision for uncertain tax positions related to accrued interest of approximately $20 million, including decreases of approximately $4 million for Entergy Arkansas, $11 million for Entergy Louisiana, and $1 million for System Energy.

2008-2009 IRS Audit

In the fourth quarter 2009, Entergy filed Applications for Change in Accounting Method (the “2009 CAM”) for tax purposes with the IRS for certain costs under Section 263A of the Internal Revenue Code.  In the Applications, Entergy proposed to treat the nuclear decommissioning liability associated with the operation of its nuclear power plants as a production cost properly includable in cost of goods sold.  The effect of the 2009 CAM was a $5.7 billion reduction in 2009 taxable income.  The 2009 CAM was adjusted to $9.3 billion in 2012.

In the fourth quarter 2012 the IRS disallowed the reduction to 2009 taxable income related to the 2009 CAM.  In the third quarter 2013, the Internal Revenue Service issued its RAR for the tax years 2008-2009. As a result of the issuance of this RAR, Entergy and the IRS resolved all of the 2008-2009 issues described above except for the 2009 CAM. Entergy disagreed with the IRS’s disallowance of the 2009 CAM and filed a protest with the IRS Appeals Division in October 2013.

In August 2015, Entergy and the IRS agreed on the treatment of the 2009 position regarding nuclear decommissioning liabilities from the 2008-2009 audit. The agreement provides that Entergy is entitled to deduct approximately $118 million of the $9.3 billion claimed in 2009. The agreement effectively settled all matters pertaining to the 2009 tax year and increased Entergy’s 2009 federal income tax liability by $2.4 million.

2010-2011 IRS Audit

The IRS examination of the 2010 and 2011 years is ongoing and the audit field work is expected to be completed by the end of the first quarter of 2016. The IRS has not issued any significant notices of proposed adjustments other than for the decommissioning liability position discussed above. The Revenue Agent’s Report is expected to be received shortly after the completion of field work.

Other Tax Matters

Entergy regularly negotiates with the IRS to achieve settlements.  The resolution of audit issues could result in significant changes to the amounts of unrecognized tax benefits in the next twelve months.

In September 2013 the U.S. Treasury Department and the IRS issued final regulations that provide guidance on the deductibility and capitalization of costs incurred associated with tangible property. Entergy and the Registrant Subsidiaries filed with the IRS an automatic application for change in accounting method which is in compliance with the final regulations and the safe harbor provisions of the relevant IRS Revenue Procedures. Entergy estimates that the effect of this accounting method change will result in a net increase to Entergy’s taxable income of approximately $585 million, which will be recognized generally over a four year period beginning with the tax year ended 2014. The adoption of the final regulations and safe harbor method results in approximate changes in the Registrant Subsidiaries taxable income as follows: an increase of $177 million for Entergy Arkansas, an increase of $78 million for Entergy Louisiana, an increase of $26 million for Entergy Mississippi, an increase of $183 million for Entergy Texas, a decrease of $2 million for Entergy New Orleans, and an increase of $22 million for System Energy.

In October 2015 two of Entergy’s Louisiana utilities, Entergy Gulf States Louisiana and Entergy Louisiana, combined their businesses into a legal entity which is identified as Entergy Louisiana herein. Entergy Louisiana maintained a carryover tax basis in the assets received. Additionally, the tax consequences provided for an increase in tax basis as well. To the extent that this increase in tax basis will provide additional tax depreciation, Entergy recorded a deferred tax asset and current tax expense resulting in a net increase in tax basis of approximately $334 million and Entergy Louisiana obtained a corresponding deferred tax asset. Consistent with the terms of an agreement with the LPSC, electric customers of Entergy Louisiana will realize customer credits associated with the business combination. Accordingly, in October 2015, Entergy recorded a regulatory liability of $107 million ($66 million net-of-tax) which partially offsets the effect of the aforementioned deferred tax asset. The deferred tax asset and the regulatory liability, net-of-tax, increased Entergy Louisiana’s member’s equity by $268 million. See Note 2 to the financial statements for further discussion of the business combination.

In the fourth quarter 2015, System Energy and Entergy Louisiana adopted a new method of accounting for income tax purposes in which the companies’ nuclear decommissioning costs will be treated as production costs of electricity includable in cost of goods sold. The new method results in a reduction of taxable income of $1.2 billion for System Energy and $2.2 billion for Entergy Louisiana.

The Protecting Americans from Tax Hikes Act of 2015 was enacted in December 2015. The most significant provisions affecting Entergy and the Registrant Subsidiaries were a five-year extension of bonus depreciation and permanent extension of the research and experimentation tax credit. The effect of the bonus depreciation extension on 2015 increased Entergy’s tax net operating loss.