Income tax expense (benefit) from continuing operations is comprised of the following components:

For the Year Ended December 31, 2011		Exelon		Generation		ComEd		PECO

Included in operations:
Federal
	Current	$	1	$	431	$	(329)	$	(71)
	Deferred		1,200		435		544		223
	Investment tax credit amortization		(12)		(7)		(3)		(2)
State
	Current		(3)		74		(123)		(37)
	Deferred		271		123		161		33

	Total	$	1,457	$	1,056	$	250	$	146

For the Year Ended December 31, 2010		Exelon		Generation		ComEd		PECO

Included in operations:
Federal
	Current	$	506	$	372	$	(203)	$	464
	Deferred		972		635		496		(276)
	Investment tax credit amortization		(12)		(7)		(3)		(2)
State
	Current		171		65		(22)		87
	Deferred		21		113		89		(121)

	Total	$	1,658	$	1,178	$	357	$	152

For the Year Ended December 31, 2009		Exelon		Generation		ComEd		PECO

Included in operations:
Federal
	Current	$	803	$	631	$	(39)	$	329
	Deferred		775		648		228		(143)
	Investment tax credit amortization		(12)		(7)		(3)		(2)
State
	Current		154		131		4		26
	Deferred		(8)		30		39		(64)

	Total	$	1,712	$	1,433	$	229	$	146

The effective income tax rate from continuing operations varies from the U.S. Federal statutory rate principally due to the following:

For the Year Ended December 31, 2011		Exelon		Generation		ComEd		PECO

U.S. Federal statutory rate		35.0	%	35.0	%	35.0	%	35.0	%
Increase (decrease) due to:
	State income taxes, net of Federal income tax benefit	4.4		4.5		3.6		(0.5)
	Qualified nuclear decommissioning trust fund income	0.5		0.7		—		—
	Domestic production activities deduction	(0.3)		(0.4)		—		—
	Tax exempt income	(0.2)		(0.2)		—		—
	Health care reform legislation	(0.2)		—		(1.0)		—
	Amortization of investment tax credit	(0.3)		(0.3)		(0.4)		(0.3)
	Production tax credits	(0.9)		(1.2)		—		—
	Plant basis differences	(1.0)		—		(0.3)		(6.9)
	Other	(0.1)		(0.7)		0.6		—

Effective income tax rate		36.9	%	37.4	%	37.5	%	27.3	%

For the Year Ended December 31, 2010		Exelon		Generation		ComEd		PECO

U.S. Federal statutory rate		35.0	%	35.0	%	35.0	%	35.0	%
Increase (decrease) due to:
	State income taxes, net of Federal income tax benefit	3.0		3.7		6.3		(4.7)
	Qualified nuclear decommissioning trust fund income	1.7		2.3		—		—
	Domestic production activities deduction	(1.2)		(1.5)		—		—
	Tax exempt income	(0.1)		(0.2)		—		—
	Health care reform legislation	1.4		0.7		1.4		1.6
	Amortization of investment tax credit	(0.3)		(0.2)		(0.4)		(0.4)
	Plant basis differences	—		—		(0.1)		0.2
	Uncertain tax position remeasurement	—		(2.0)		9.0		—
	Other	(0.2)		(0.4)		0.2		0.2

Effective income tax rate		39.3	%	37.4	%	51.4	%	31.9	%

For the Year Ended December 31, 2009		Exelon		Generation		ComEd		PECO

U.S. Federal statutory rate		35.0	%	35.0	%	35.0	%	35.0	%
Increase (decrease) due to:
	State income taxes, net of Federal income tax benefit	2.1		3.0		4.7		(5.0)
	Qualified nuclear decommissioning trust fund losses	3.1		3.8		—		—
	Domestic production activities deduction	(0.9)		(1.1)		—		—
	Tax exempt income	(0.1)		(0.2)		—		—
	Nontaxable postretirement benefits	(0.2)		(0.2)		(0.5)		(0.3)
	Amortization of investment tax credit	(0.2)		(0.1)		(0.5)		(0.4)
	Plant basis differences	—		—		(0.3)		(0.1)
	Other	(0.1)		0.1		(0.4)		0.1

Effective income tax rate		38.7	%	40.3	%	38.0	%	29.3	%

The tax effects of temporary differences, which give rise to significant portions of the deferred tax assets (liabilities), as of December 31, 2011 and 2010 are presented below:

For the Year Ended December 31, 2011			Exelon		Generation		ComEd		PECO

	Plant basis differences		$	(7,803)	$	(2,670)	$	(3,264)	$	(2,238)
	Unrealized gains on derivative financial
		instruments		(468)		(737)		(4)		—
	Deferred pension and post-retirement obligation			665		(520)		(623)		(31)
	Nuclear decommissioning activities			(452)		(452)		—		—
	Deferred debt refinancing costs			(37)		—		(31)		(6)
	Other, net			41		338		16		135

Deferred income tax liabilities (net)			$	(8,054)	$	(4,041)	$	(3,906)	$	(2,140)
Unamortized investment tax credits				(200)		(169)		(26)		(5)

Total deferred income tax liabilities (net) and unamortized
	investment tax credits		$	(8,254)	$	(4,210)	$	(3,932)	$	(2,145)

For the Year Ended December 31, 2010			Exelon		Generation		ComEd		PECO

	Plant basis differences		$	(5,931)	$	(1,961)	$	(2,552)	$	(1,811)
	Unrealized gains on derivative financial
		instruments		(523)		(908)		(4)		(1)
	Deferred pension and post-retirement obligation			485		(550)		(635)		(37)
	Nuclear decommissioning activities			(444)		(444)		—		—
	Deferred debt refinancing costs			(46)		—		(38)		(7)
	Goodwill			4		(1)		—		—
	Other, net			(39)		295		65		81

Deferred income tax liabilities (net)			$	(6,494)	$	(3,569)	$	(3,164)	$	(1,775)
Unamortized investment tax credits				(212)		(176)		(29)		(7)

Total deferred income tax liabilities (net) and unamortized
	investment tax credits		$	(6,706)	$	(3,745)	$	(3,193)	$	(1,782)

The following table provides the Registrants' carryforwards and any corresponding valuation allowances as of December 31, 2011. Generation and ComEd do not have any carryforwards as of December 31, 2011.

(a) Exelon's state net operating loss carryforwards will expire beginning in 2019.

The following table provides a reconciliation of the Registrants' unrecognized tax benefits as of December 31, 2011, 2010 and 2009:

	Exelon		Generation		ComEd		PECO

Unrecognized tax benefits at January 1, 2011	$	787	$	664	$	72	$	44
Increases based on tax positions related to 2011		5		1		—		4
Change to positions that only affect timing		21		24		(2)		—
Decreases based on tax positions prior to 2011		(3)		(3)		—		—
Decreases from expiration of statute of limitations		(3)		(3)		—		—

Unrecognized tax benefits at December 31, 2011	$	807	$	683	$	70	$	48

	Exelon		Generation		ComEd		PECO

Unrecognized tax benefits at January 1, 2010	$	1,498	$	633	$	471	$	372
Increases based on tax positions related to 2010		1		—		—		—
Decreases based on tax positions related to 2010		(2)		(2)		—		—
Change to positions that only affect timing		(262)		55		(3)		(328)
Increases based on tax positions prior to 2010		8		8		—		—
Decreases based on tax positions prior to 2010		(3)		(3)		—		—
Decreases related to settlements with taxing authorities		(452)		(26)		(396)		—
Decrease from expiration of statute of limitations		(1)		(1)		—		—

Unrecognized tax benefits at December 31, 2010	$	787	$	664	$	72	$	44

	Exelon		Generation		ComEd		PECO

Unrecognized tax benefits at January 1, 2009	$	1,495	$	468	$	635	$	365
Decreases based on tax positions related to 2009		(2)		(2)		—		—
Change to positions that only affect timing		19		172		(154)		7
Increases based on tax positions prior to 2009		4		3		—		—
Decreases related to settlements with taxing authorities		(18)		(8)		(10)		—

Unrecognized tax benefits at December 31, 2009	$	1,498	$	633	$	471	$	372

Included in Exelon's unrecognized tax benefits balance at December 31, 2011 and 2010 are approximately $804 million and $783 million, respectively, of tax positions for which the ultimate tax benefit is highly certain, but for which there is uncertainty about the timing of such benefits. The disallowance of such positions would not materially affect the annual effective tax rate but would accelerate the payment of cash to or defer the receipt of the cash tax benefit from the taxing authority to an earlier or later period respectively.

Unrecognized tax benefits that if recognized would affect the effective tax rate

Exelon and Generation have $3 million and $3 million, respectively, of unrecognized tax benefits at December 31, 2011 that, if recognized, would decrease the effective tax rate. Exelon and Generation had $4 million and $4 million, respectively, of unrecognized tax benefits at December 31, 2010 that, if recognized, would decrease the effective tax rate.

The following table represents the net interest receivable (payable), including interest related to uncertain tax positions reflected in the Registrants' Consolidated Balance Sheets.

1999 Sale of Fossil Generating Assets (Exelon and ComEd). Exelon, through its ComEd subsidiary, took two positions on its 1999 income tax return to defer approximately $2.8 billion of tax gain on the 1999 sale of ComEd's fossil generating assets. Exelon deferred approximately $1.6 billion of the gain under the involuntary conversion provisions of the IRC. Exelon believes that it was economically compelled to dispose of ComEd's fossil generating plants as a result of the Illinois Act and that the proceeds from the sale of the fossil plants were properly reinvested in qualifying replacement property such that the gain could be deferred over the lives of the replacement property under the involuntary conversion provisions. The remaining approximately $1.2 billion of the gain was deferred by reinvesting the proceeds from the sale in qualifying replacement property under the like-kind exchange provisions of the IRC. The like-kind exchange replacement property purchased by Exelon included interests in three municipal-owned electric generation facilities which were properly leased back to the municipalities.

Exelon received the IRS audit report for 1999 through 2001, which reflected the full disallowance of the deferral of gain associated with both the involuntary conversion position and the like-kind exchange transaction. Specifically, the IRS asserted that ComEd was not forced to sell the fossil generating plants and the sales proceeds were therefore not received in connection with an involuntary conversion of certain ComEd property rights. Accordingly, the IRS asserted that the gain on the sale of the assets was fully subject to tax. The IRS also asserted that the Exelon purchase and leaseback transaction is substantially similar to a leasing transaction, known as a SILO, which the IRS does not respect as the acquisition of an ownership interest in property. A SILO is a “listed transaction” that the IRS has identified as a potentially abusive tax shelter under guidance issued in 2005. Accordingly, the IRS has asserted that the sale of the fossil plants followed by the purchase and leaseback of the municipal owned generation facilities does not qualify as a like-kind exchange and the gain on the sale is fully subject to tax.

Competitive Transition Charges (Exelon, ComEd, and PECO). Exelon contended that the Illinois Act and the Competition Act resulted in the taking of certain of ComEd's and PECO's assets used in their respective businesses of providing electricity services in their defined service areas. Exelon has filed refund claims with the IRS taking the position that CTCs collected during ComEd's and PECO's transition periods represent compensation for that taking and, accordingly, are excludible from taxable income as proceeds from an involuntary conversion. The tax basis of property acquired with the funds provided by the CTCs would be reduced such that the benefits of the position are temporary in nature. The IRS disallowed the refund claims for the 1999-2001 tax years.

Under the Illinois Act, ComEd was required to allow competitors the use of its distribution system resulting in the taking of ComEd's assets and lost asset value (stranded costs). As compensation for the taking, ComEd was permitted to collect a portion of the stranded costs through the collection of CTCs from those customers electing to purchase electricity from providers other than ComEd. ComEd collected approximately $1.2 billion in CTCs for the years 1999-2006.

Similarly, under the Competition Act, PECO was required to allow others the use of its distribution system resulting in the taking of PECO's assets and the stranded costs. Pennsylvania permitted PECO to collect CTCs as compensation for its stranded costs. The PAPUC determined the total amount of stranded costs that PECO was permitted to collect through the CTCs to be $5.3 billion.

2009 Status of Tax Positions. During 2009, Exelon held discussions with IRS Appeals in an attempt to reach a settlement on both the involuntary conversion and like-kind exchange positions, in a manner commensurate with Exelon's and the IRS' respective hazards of litigation with respect to each issue. During the second quarter of 2009, Exelon determined that a settlement with IRS Appeals was unlikely and that Exelon would be required to initiate litigation in order to resolve the issues. Accordingly, Exelon concluded that it had sufficient new information that a remeasurement of these two positions was required in accordance with applicable accounting standards. As a result, Exelon recorded a $31 million (after-tax) interest benefit of which $40 million (after-tax) was recorded at ComEd. The difference in amounts recorded at Exelon and ComEd is due to the method of allocating interest to the Registrants.

Due to the fact that tax litigation often results in a negotiated settlement, as of December 31, 2009, Exelon believed that an eventual settlement on the involuntary conversion position remained a likely outcome. Therefore, Exelon and ComEd established a liability for an unrecognized tax benefit consistent with their view as to a likely settlement.

With regard to the like-kind exchange transaction, as of December 31, 2009, Exelon believed it was likely that the issue would be fully litigated. Exelon assessed in accordance with accounting standards whether it would prevail in litigation. While Exelon recognized the complexity and hazards of this litigation, it believed that it was more likely than not that it would prevail in such litigation and therefore eliminated any liability for unrecognized tax benefits.

In addition to attempting to impose tax on the transactions, the IRS had asserted penalties of approximately $196 million for a substantial understatement of tax. Because Exelon believed it was unlikely that the penalty assertion would ultimately be sustained, Exelon and ComEd had not recorded a liability for penalties as of December 31, 2009.

2010 Status of Tax Positions. In connection with Exelon's discussions with IRS Appeals during the second quarter of 2010, IRS Appeals proposed a settlement offer for the like-kind exchange transaction and involuntary conversion and CTC positions.

Based on the status of these settlement discussions, Exelon concluded that it had sufficient new information that a remeasurement of the involuntary conversion and CTC positions was required in accordance with applicable accounting standards. As a result of the required re-measurement in the second quarter of 2010, Exelon recorded $65 million (after-tax) of interest expense, of which $36 million (after-tax) and $22 million (after-tax) were recorded at ComEd and PECO, respectively. ComEd also recorded a current tax expense of $70 million offset with a tax benefit recorded at Generation of $70 million. In the third quarter of 2010, Exelon and IRS Appeals reached a nonbinding, preliminary agreement to settle Exelon's involuntary conversion and CTC positions. The agreement is consistent with IRS Appeals' second quarter 2010 offer to settle the involuntary conversion and CTC positions and also includes IRS Appeals' agreement to withdraw its assertion of the $110 million substantial understatement penalty with respect to Exelon's involuntary conversion position. Final resolution of the involuntary conversion and CTC disputes remains subject to finalizing terms and calculations and executing definitive agreements satisfactory to both parties. As a result of the preliminary agreement, Exelon and ComEd eliminated any liability for unrecognized tax benefits and established a current tax payable to the IRS.

2011 Status of Tax Positions. Under the terms of the preliminary agreement, Exelon estimates that the IRS will assess tax and interest of approximately $300 million in 2012 for the years for which there is a resulting tax deficiency, of which $405 million would be paid by ComEd, $135 million would be received by PECO, $10 million would be paid by Generation and the remainder received by Exelon. These amounts are net of approximately $300 million of refunds due from the settlement of the 2001 tax method of accounting change for certain overhead costs under the SSCM as well as other agreed upon audit adjustments. In order to stop additional interest from accruing on the expected assessment, Exelon made a payment in December 2010 to the IRS of $302 million. During 2011, ComEd reimbursed Exelon for this amount. Further, Exelon expects to receive additional tax refunds of approximately $365 million between 2012 and 2014, of which $55 million and $335 million would be received by Generation and ComEd, respectively, and the remainder paid by Exelon.

Exelon and IRS Appeals to date have failed to reach a settlement with respect to the like-kind exchange position. Exelon continues to believe that its like-kind exchange transaction is not the same as or substantially similar to a SILO and does not believe that the concession demanded by the IRS in its settlement offer reflects the strength of Exelon's position. IRS Appeals also continues to assert an $86 million penalty for a substantial understatement of tax with respect to the like-kind exchange position.

While Exelon has been and remains willing to settle the issue in a manner generally commensurate with its hazards of litigation, the IRS has thus far been unwilling to settle the issue without requiring a nearly complete concession of the issue by Exelon. Accordingly, to continue to contest the IRS's disallowance of the like-kind exchange position and its assertion of the $86 million substantial understatement penalty, Exelon expects to initiate litigation in 2012 after the final resolution of the involuntary conversion and CTC settlement. Given that Exelon has determined settlement is not a realistic outcome, it has assessed in accordance with applicable accounting standards whether it will prevail in litigation. While Exelon recognizes the complexity and hazards of this litigation, it believes that it is more likely than not that it will prevail in such litigation and therefore eliminated any liability for unrecognized tax benefits. Further, Exelon believes it is unlikely that the penalty assertion will ultimately be sustained, Exelon and ComEd have not recorded a liability for penalties. However, should the IRS prevail in asserting the penalty it would result in an after-tax charge of $86 million to Exelon's and ComEd's results of operations.

As of December 31, 2011, assuming Exelon's preliminary settlement of the involuntary conversion position is finalized, the potential tax and interest, exclusive of penalties, that could become currently payable in the event of a fully successful IRS challenge to Exelon's like-kind exchange position could be as much as $860 million, of which $550 million would be paid by ComEd and the remainder by Exelon. If the IRS were to prevail in litigation on the like-kind exchange position, Exelon's results of operations could be negatively affected due to increased interest expense, as of December 31, 2011, by as much as $260 million (after-tax), of which $200 million would be recorded at ComEd and the remainder by Exelon. Litigation could take several years such that the estimated cash and interest impacts would likely change by a material amount.

Based on Exelon management's expectations as to the potential of a settlement and litigation outcome, it is reasonably possible that the unrecognized tax benefits related to these issues may significantly change within the next 12 months. It is not possible at this time to predict the amount, if any, of such a change.

Nuclear Decommissioning Trust Fund Special Transfer Tax Deduction (Exelon and Generation)

During 2008, Generation benefited from a provision in the Energy Policy Act of 2005 which allowed companies an income tax deduction for a “special transfer” of funds from a non-tax qualified NDT fund to a qualified NDT fund. As a result of temporary guidance published by the U.S. Department of Treasury, Generation completed a special transfer in the first quarter of 2008 for tax year 2008. In December 2010, the U.S. Department of Treasury issued final regulations under IRC Section 468A. The final regulations included a transitional relief provision that allowed taxpayers to request permission from the IRS to designate a taxable year, as far back as 2006, during which the special transfer will be deemed to have occurred. Exelon determined, and confirmed with the IRS through the ruling process, that this provision allows a majority of Generation's 2008 special transfer deduction to be claimed in the 2006 tax year and the remaining portions claimed ratably in taxable years 2007 and 2008. On February 18, 2011, in order to preserve both the ability to designate the special transfer from 2008 to an earlier taxable year and the ability to complete future additional special transfers, Exelon filed ruling requests with the IRS. During 2011, Exelon received favorable rulings from the IRS on all of its ruling requests. As a result, Exelon recorded an interest and tax benefit of $46 million, net of tax including the impact on the manufacturer's deduction, in 2011 related to the special transfers completed in 2008 and 2011.

The Taxpayer Accountability and Budget Stabilization Act, (SB 2505), enacted into law in Illinois on January 13, 2011, increases the corporate tax rate in Illinois from 7.3% to 9.5% for tax years 2011 – 2014, provides for a reduction in the rate from 9.5% to 7.75% for tax years 2015 – 2024 and further reduces the rate from 7.75% to 7.3% for tax years 2025 and thereafter. Pursuant to the rate change, Exelon reevaluated its deferred state income taxes during the first quarter of 2011. Illinois' corporate income tax rate changes resulted in a charge to state deferred taxes (net of Federal taxes) during the first quarter of 2011 of $7 million, $11 million and $4 million for Exelon, Generation and ComEd, respectively. Exelon's and ComEd's charge is net of a regulatory asset of $15 million.

In 2011, the income tax rate change increased Exelon's Illinois income tax provision (net of Federal taxes) by approximately $7 million, of which $12 million and $5 million of additional tax relates to Exelon Corporate and Generation, respectively, and a $10 million benefit for ComEd. The 2011 tax benefit at ComEd reflects the impact of a 2011 tax net operating loss generated primarily by the bonus depreciation deduction allowed under the Tax Relief Act of 2010 and the electric transmission and distribution property repairs deduction discussed below.

Exelon and Generation periodically review events that may significantly impact how income is apportioned among the states and, therefore, the calculation of Exelon's and Generation's deferred state income taxes. On April 16, 2009, the PAPUC approved PECO's electricity procurement proposal that has an impact on Exelon's and Generation's apportionment of income among the states. Accordingly, Exelon and Generation re-evaluated the impacts to deferred state taxes in the second quarter of 2009. The effect of such evaluations resulted in the recording of a non-cash deferred state tax benefit in the amount of $35 million, net of taxes. In 2010, the Registrants performed a review of the long-term state tax rates and noted no significant events that would materially impact state apportionment. As such, there was no update to the long-term state apportionment rates in 2010. In 2011 as a result of the 2011 Illinois State Tax Rate Legislation discussed above, Exelon and Generation reevaluated their long-term state tax apportionment for Illinois and all other states where they have state income tax obligations. The effect of revising the long-term state tax apportionment resulted in the recording of a deferred state tax expense during the first quarter of 2011 of $22 million and $11 million (net of Federal taxes) for Exelon and Generation, respectively. The long-term state tax apportionment also was revised in the fourth quarter of 2011 pursuant to long-term state tax apportionment policy, resulting in recording an additional deferred state tax expense of $1 million and a deferred state tax benefit of $8 million (net of Federal taxes) for Exelon and Generation, respectively.

On February 20, 2009, the Illinois Supreme Court ruled in Exelon's favor in a case involving refund claims for Illinois investment tax credits. Responding to the Illinois Attorney General's petition for rehearing, on July 15, 2009, the Illinois Supreme Court modified its opinion to indicate that it was to be applied only prospectively, beginning in 2009. In the third quarter of 2009, Exelon, Generation and ComEd decreased their unrecognized tax benefits related to this position. On December 22, 2009, Exelon filed a Petition of Writ for Certiorari with the United States Supreme Court appealing the Illinois Supreme Court's July 15, 2009 modified opinion. On March 1, 2010, the United States Supreme Court announced that it would not review the Illinois Supreme Court's decision. As a result of the United States Supreme Court decision, Exelon, Generation and ComEd ceased reporting their unrecognized tax benefits as of March 31, 2010.

Pursuant to authoritative guidance issued by the Pennsylvania Department of Revenue on February 24, 2011, Exelon is permitted to deduct 100% bonus depreciation in Pennsylvania in the year that such depreciation is claimed and allowable for Federal purposes. For Federal purposes, qualifying property placed into service after September 8, 2010, and before January 1, 2012, is eligible for 100% bonus depreciation. During 2011, the bonus depreciation deduction resulted in a benefit of approximately $7 million, $1 million and $6 million associated with property placed in service in 2010 at Exelon, Generation and PECO, respectively.

Accounting for Electric Transmission and Distribution Property Repairs (Exelon, Generation, ComEd and PECO)

On August 19, 2011, the IRS issued Revenue Procedure 2011-43 providing a safe harbor method of tax accounting for repair costs associated with electric transmission and distribution property. ComEd intends to adopt the safe harbor in the Revenue Procedure for the 2011 tax year. PECO adopted the safe harbor for the 2010 tax year. For the year ended December 31, 2011, the adoption of the safe harbor resulted in a $35 million reduction to income tax expense at PECO, while Generation incurred additional income tax expense in the amount of $28 million due to a decrease in its manufacturer's deduction, which are reflected in the effective income tax rate reconciliation above in the plant basis differences and domestic production activities deduction lines, respectively. For Exelon, the adoption had a minimal effect on consolidated earnings. In addition, the adoption of the safe harbor will result in a cash tax benefit at Exelon, ComEd and PECO in the amount of approximately $300 million, $250 million and $95 million, respectively, partially offset by a cash tax detriment at Generation in the amount of $28 million.

See Note 2 – Regulatory Matters for discussion of the regulatory treatment prescribed in the 2010 electric distribution rate case settlement for PECO's cash tax benefit resulting from the application of the method change to years prior to 2010.

Generation, ComEd and PECO are all party to an agreement with Exelon and other subsidiaries of Exelon that provides for the allocation of consolidated tax liabilities and benefits (Tax Sharing Agreement). The Tax Sharing Agreement provides that each party is allocated an amount of tax similar to that which would be owed had the party been separately subject to tax. In addition, any net benefit attributable to Exelon is reallocated to the other Registrants. That allocation is treated as a contribution to the capital of the party receiving the benefit. During 2011, Generation and PECO recorded an allocation of Federal tax benefits from Exelon under the Tax Sharing Agreement of $30 million and $18 million, respectively. During 2011, ComEd did not record an allocation of Federal tax benefits from Exelon under the Tax Sharing Agreement as a result of ComEd's 2011 tax net operating loss generated primarily by the bonus depreciation deduction allowed under the Tax Relief Act of 2010 and the electric transmission and distribution property repairs deduction discussed above. During 2010, Generation, ComEd and PECO recorded an allocation of Federal tax benefits from Exelon under the Tax Sharing Agreement of $60 million, $2 million and $43 million, respectively. During 2009, Generation, ComEd and PECO recorded an allocation of Federal tax benefits from Exelon under the Tax Sharing Agreement of $57 million, $8 million and $27 million, respectively.

In addition, ComEd received a non-cash contribution to equity from Exelon of $11 million related to tax benefits associated with capital projects constructed by ComEd on behalf of Exelon and Generation.