Income Taxes:

The income tax rate of 34.6% was unchanged for the nine months ended September 30, 2015 compared with the nine months ended September 30, 2014. The income tax rate of 33.2% for the three months ended September 30, 2015 decreased 0.7 percentage points from the three months ended September 30, 2014, due primarily to the following:


▪	the reversal of $59 million of tax reserves and associated interest due primarily to the closure in August 2015 of the IRS audit of Altria Group, Inc. and its consolidated subsidiaries’ 2007-2009 tax years (“IRS 2007-2009 Audit”) that was recorded during the third quarter of 2015; and


▪	the resolution of various Kraft Foods Inc. (now known as Mondelēz International, Inc. (“Mondelēz”)) and Philip Morris International Inc. (“PMI”) tax matters in the third quarters of 2015 and 2014, as discussed further below;

partially offset by:


▪	a $41 million reversal of foreign tax credits primarily associated with SABMiller dividends that was recorded during the third quarter of 2015; and


▪	a $19 million reversal of tax accruals no longer required that was recorded during the third quarter of 2014.

As discussed in the 2014 Form 10-K, Altria Group, Inc. recognizes accrued interest and penalties associated with uncertain tax positions as part of the provision for income taxes on its condensed consolidated statements of earnings. At September 30, 2015, Altria Group, Inc. had $12 million of accrued interest and penalties included in its liability for tax contingencies. At December 31, 2014, Altria Group, Inc. had $57 million of accrued interest and penalties included in its liability for tax contingencies, of which approximately $7 million related to PMI, for which PMI was responsible under its tax sharing agreement discussed further below.

Under tax sharing agreements entered into in connection with the 2007 and 2008 spin-offs between Altria Group, Inc. and its former subsidiaries Mondelēz and PMI, respectively, Mondelēz and PMI are responsible for their respective pre-spin-off tax obligations. Altria Group, Inc., however, remains severally liable for Mondelēz’s and PMI’s pre-spin-off federal tax obligations pursuant to regulations governing federal consolidated income tax returns, and continued to include the pre-spin-off federal income tax reserves of Mondelēz and PMI in its liability for uncertain tax positions. As of September 30, 2015, there were no remaining pre-spin-off tax reserves related to PMI, and as of December 31, 2014, there were no remaining pre-spin-off tax reserves related to Mondelēz.

During the third quarters of 2015 and 2014, net tax benefits of $41 million and $5 million, respectively, were recorded for Mondelēz and PMI tax matters relating to the IRS 2007-2009 Audit. These net tax benefits were offset by changes to Mondelēz and PMI tax-related receivables/payables, which were recorded as decreases to operating income on Altria Group, Inc.’s condensed consolidated statements of earnings. Due to the respective offsets, the Mondelēz and PMI tax matters had no impact on Altria Group, Inc.’s net earnings for the nine and three months ended September 30, 2015 and 2014.

Altria Group, Inc.’s U.S. subsidiaries join in the filing of a U.S. federal consolidated income tax return. The U.S. federal statute of limitations remains open for the year 2007 and forward, with years 2010 to 2013 currently under examination by the IRS as part of an audit conducted in the ordinary course of business.

Altria Group, Inc. is subject to income taxation in many jurisdictions. Uncertain tax positions reflect the difference between tax positions taken or expected to be taken on income tax returns and the amounts recognized in the financial statements. Resolution of the related tax positions with the relevant tax authorities may take many years to complete, and such timing is not entirely within the control of Altria Group, Inc. At September 30, 2015, Altria Group, Inc.’s total unrecognized tax benefits were $135 million. The amount of unrecognized tax benefits that, if recognized, would impact the effective tax rate at September 30, 2015 was $86 million, along with $49 million affecting deferred taxes. It is reasonably possible that within the next 12 months certain examinations will be resolved, which could result in a decrease in unrecognized tax benefits of approximately $5 million. At December 31, 2014, Altria Group, Inc.’s total unrecognized tax benefits were $258 million. The amount of unrecognized tax benefits that, if recognized, would impact the effective tax rate at December 31, 2014 was $207 million, along with $51 million affecting deferred taxes. However, the impact on net earnings at December 31, 2014 would be $177 million, as a result of a net receivable from PMI of $30 million.