Income Taxes

12 Months Ended

Dec. 31, 2021

Income Taxes [Line Items]

Income Taxes

Income Taxes

A reconciliation of reported income tax expense for PSEG with the amount computed by multiplying pre-tax income by the statutory federal income tax rate of 21% is as follows:

	Years Ended December 31,
PSEG	2021			2020			2019
	Millions
Net Income (Loss)	$	(648)		$	1,905		$	1,693
Income Taxes:
Operating Income:
Current (Benefit) Expense:
Federal	$	407		$	385		$	84
State	(3)			48			18
Total Current	404			433			102
Deferred Expense (Benefit):
Federal	(700)			(164)			3
State	(136)			141			132
Total Deferred	(836)			(23)			135
ITC	(9)			(14)			20
Total Income Tax Expense (Benefit)	$	(441)		$	396		$	257
Pre-Tax Income (Loss)	$	(1,089)		$	2,301		$	1,950
Tax Computed at Statutory Rate @ 21%	$	(229)		$	483		$	410
Increase (Decrease) Attributable to Flow-Through of Certain Tax Adjustments:
State Income Taxes (net of federal income tax)	(109)			147			117
Uncertain Tax Positions	19			3			—
NDT Fund	23			32			34
Plant-Related Items	(7)			(9)			(2)
Tax Credits	29			(18)			(18)
Audit Settlement	(8)			(27)			—
Leasing Activities	(1)			(35)			—
GPRC-CEF-EE	(13)			—			—
TAC	(171)			(205)			(272)
Bad Debt Flow-Through	27			28			—
Other	(1)			(3)			(12)
Subtotal	(212)			(87)			(153)
Total Income Tax Expense (Benefit)	$	(441)		$	396		$	257
Effective Income Tax Rate	40.5		%	17.2		%	13.2		%

The following is an analysis of deferred income taxes for PSEG:

	As of December 31,
PSEG	2021		2020
	Millions
Deferred Income Taxes
Assets:
Noncurrent:
Regulatory Liability Excess Deferred Tax	$	439	$	485
OPEB	107		135
Bad Debt	67		40
Related to Uncertain Tax Positions	30		29
Interest Disallowance Carryforward	—		39
Operating Leases	48		60
Other	253		130
Total Noncurrent Assets	$	944	$	918
Liabilities:
Noncurrent:
Plant-Related Items	$	4,701	$	5,163
New Jersey Corporate Business Tax	939		1,016
Leasing Activities	113		133
AROs and NDT Fund	270		324
Taxes Recoverable Through Future Rates (net)	120		114
Pension Costs	169		97
Operating Leases	43		55
Other	271		247
Total Noncurrent Liabilities	$	6,626	$	7,149
Summary of Accumulated Deferred Income Taxes:
Net Noncurrent Deferred Income Tax Liabilities	$	5,682	$	6,231
ITC	77		271
Net Total Noncurrent Deferred Income Taxes and ITC	$	5,759	$	6,502

The deferred tax effect of certain assets and liabilities is presented in the table above net of the deferred tax effect associated with the respective regulatory deferrals.

A reconciliation of reported income tax expense for PSE&G with the amount computed by multiplying pre-tax income by the statutory federal income tax rate of 21% is as follows:

	Years Ended December 31,
PSE&G	2021			2020			2019
	Millions
Net Income	$	1,446		$	1,327		$	1,250
Income Taxes:
Operating Income:
Current (Benefit) Expense:
Federal	$	208		$	179		$	121
State	1			8			—
Total Current	209			187			121
Deferred Expense (Benefit):
Federal	(33)			(71)			(156)
State	153			128			117
Total Deferred	120			57			(39)
ITC	(5)			(4)			11
Total Income Tax Expense	$	324		$	240		$	93
Pre-Tax Income	$	1,770		$	1,567		$	1,343
Tax Computed at Statutory Rate @ 21%	$	372		$	329		$	282
Increase (Decrease) Attributable to Flow-Through of Certain Tax Adjustments:
State Income Taxes (net of federal income tax)	122			106			92
Uncertain Tax Positions	2			4			1
Plant-Related Items	(7)			(9)			(2)
Tax Credits	(8)			(9)			(8)
Audit Settlement	(1)			(2)			—
GPRC-CEF-EE	(13)			—			—
TAC	(171)			(205)			(272)
Bad Debt Flow-Through	27			28			—
Other	1			(2)			—
Subtotal	(48)			(89)			(189)
Total Income Tax Expense	$	324		$	240		$	93
Effective Income Tax Rate	18.3		%	15.3		%	6.9		%

The following is an analysis of deferred income taxes for PSE&G:

	As of December 31,
PSE&G	2021		2020
	Millions
Deferred Income Taxes
Assets:
Noncurrent:
Regulatory Liability Excess Deferred Tax	$	439	$	485
OPEB	61		82
Bad Debt	67		40
Operating Leases	20		21
Other	57		52
Total Noncurrent Assets	$	644	$	680
Liabilities:
Noncurrent:
Plant-Related Items	$	4,006	$	3,874
New Jersey Corporate Business Tax	863		721
Pension Costs	180		166
Taxes Recoverable Through Future Rates (net)	120		114
Conservation Costs	75		61
Operating Leases	19		21
Related to Uncertain Tax Positions	1		5
Other	178		161
Total Noncurrent Liabilities	$	5,442	$	5,123
Summary of Accumulated Deferred Income Taxes:
Net Noncurrent Deferred Income Tax Liabilities	$	4,798	$	4,443
ITC	76		81
Net Total Noncurrent Deferred Income Taxes and ITC	$	4,874	$	4,524

The deferred tax effect of certain assets and liabilities is presented in the table above net of the deferred tax effect associated with the respective regulatory deferrals.

PSEG and PSE&G each provide deferred taxes at the enacted statutory tax rate for all temporary differences between the financial statement carrying amounts and the tax bases of assets and liabilities irrespective of the treatment for rate-making purposes. Management believes that it is probable that the accumulated tax benefits that previously have been treated as a flow-through item to PSE&G customers will be recovered from or refunded to PSE&G’s customers in the future. See Note 7. Regulatory Assets and Liabilities.

The 2018 decrease in the federal tax rate resulted in PSE&G recording excess deferred income taxes. As of December 31, 2020, the balance was approximately $1.7 billion with a Regulatory Liability of approximately $2.4 billion. In 2021, PSE&G returned approximately $238 million of excess deferred income taxes and previously realized and current period deferred income taxes related to tax repair deductions to its customers with a reduction to tax expense of approximately $171 million. The flowback to customers of the excess deferred income taxes and previously realized tax repair deductions resulted in a decrease of approximately $215 million in the Regulatory Liability. The current period tax repair deduction reduces tax expense and revenue and recognizes a Regulatory Asset as PSE&G believes it is probable that the current period tax repair deductions flowed through to the customers will be recovered from customers in the future. See Note 7. Regulatory Assets and Liabilities for additional information.

In March 2020, the federal Coronavirus Aid, Relief, and Economic Security Act (CARES Act) was enacted. Among other provisions, the CARES Act allows a five-year carryback of any net operating loss (NOL) generated in a taxable year beginning after December 31, 2017, and before January 1, 2021.

In April 2020, the IRS issued a private letter ruling (PLR) to PSE&G concluding that certain excess deferred taxes previously classified as protected should be classified as unprotected. Unprotected excess deferred income taxes are not subject to the normalization rules allowing them to be refunded to customers sooner as agreed to with FERC and the BPU. In July 2020, FERC and the BPU approved PSE&G’s requests to refund these unprotected excess deferred income taxes to customers. FERC approved the refund of these unprotected excess deferred income taxes within the 2019 true-up filing. The BPU approved the refund of these unprotected excess deferred income taxes beginning in July 2020 through December 31, 2024.

In July 2020, the IRS issued final and proposed regulations addressing the limitation on deductible business interest expense contained in the Tax Act. These regulations retroactively allow depreciation to be added back in computing the 30% adjusted taxable income (ATI) cap, increasing the amount of interest that can be deducted by unregulated businesses in years before 2022. For 2022 and after, the regulations continue to disallow the addback of depreciation in the computation of ATI, effectively lowering the cap on the amount of deductible business interest and contain special rules in allocating interest between regulated and non-regulated businesses. The portion of PSEG’s and PSEG Power’s business interest expense that was disallowed in 2018 and 2019 under the previously issued proposed regulations will now be deductible in those respective years.

In March 2021, PSEG amended its 2018 federal income tax return to deduct the previously disallowed business interest expense in accordance with the final and proposed regulations issued in July 2020. The 2018 amended return generated a NOL that was carried back to 2013 as provided by the CARES Act.

PSEG expects that a prolonged economic recovery may result in additional federal or state tax legislation that can have a material impact on PSEG’s and PSE&G’s tax expense and cash tax position.

Amounts recorded under the Tax Act and CARES Act are subject to change based on several factors, including whether the IRS or state taxing authorities issue additional guidance and/or further clarification. Any further guidance or clarification could impact PSEG’s and PSE&G’s financial statements.

As of December 31, 2021, PSE&G had a $15 million New Jersey Corporate Business Tax NOL that is expected to be fully realized in the future. There are no other material tax carryforwards in other jurisdictions.

PSEG recorded the following amounts related to its unrecognized tax benefits, which were primarily comprised of amounts recorded for PSE&G and PSEG’s other subsidiaries:

2021	PSEG		PSE&G
	Millions
Total Amount of Unrecognized Tax Benefits as of January 1, 2021	$	147	$	30
Increases as a Result of Positions Taken in a Prior Period	58		8
Decreases as a Result of Positions Taken in a Prior Period	(19)		(12)
Increases as a Result of Positions Taken during the Current Period	6		1
Decreases as a Result of Positions Taken during the Current Period	—		—
Decreases as a Result of Settlements with Taxing Authorities	—		—
Decreases due to Lapses of Applicable Statute of Limitations	—		—
Total Amount of Unrecognized Tax Benefits as of December 31, 2021	$	192	$	27
Accumulated Deferred Income Taxes Associated with Unrecognized Tax Benefits	(76)		(15)
Regulatory Asset—Unrecognized Tax Benefits	(7)		(7)
Total Amount of Unrecognized Tax Benefits that if Recognized, would Impact the Effective Tax Rate (including Interest and Penalties)	$	109	$	5

2020	PSEG		PSE&G
	Millions
Total Amount of Unrecognized Tax Benefits as of January 1, 2020	$	321	$	124
Increases as a Result of Positions Taken in a Prior Period	33		21
Decreases as a Result of Positions Taken in a Prior Period	(91)		(51)
Increases as a Result of Positions Taken during the Current Period	—		—
Decreases as a Result of Positions Taken during the Current Period	—		—
Decreases as a Result of Settlements with Taxing Authorities	(116)		(64)
Decreases due to Lapses of Applicable Statute of Limitations	—		—
Total Amount of Unrecognized Tax Benefits as of December 31, 2020	$	147	$	30
Accumulated Deferred Income Taxes Associated with Unrecognized Tax Benefits	(69)		(12)
Regulatory Asset—Unrecognized Tax Benefits	(15)		(15)
Total Amount of Unrecognized Tax Benefits that if Recognized, would Impact the Effective Tax Rate (including Interest and Penalties)	$	63	$	3

In April 2020, the Joint Committee on Taxation approved PSEG’s nuclear carryback claim and federal tax returns for the years 2011 and 2012. In June 2020, the federal income tax audits for years 2011 through 2016 and the nuclear carryback claim were concluded.

2019	PSEG		PSE&G
	Millions
Total Amount of Unrecognized Tax Benefits as of January 1, 2019	$	318	$	108
Increases as a Result of Positions Taken in a Prior Period	17		5
Decreases as a Result of Positions Taken in a Prior Period	(37)		(1)
Increases as a Result of Positions Taken during the Current Period	27		12
Decreases as a Result of Positions Taken during the Current Period	—		—
Decreases as a Result of Settlements with Taxing Authorities	(4)		—
Decreases due to Lapses of Applicable Statute of Limitations	—		—
Total Amount of Unrecognized Tax Benefits as of December 31, 2019	$	321	$	124
Accumulated Deferred Income Taxes Associated with Unrecognized Tax Benefits	(184)		(71)
Regulatory Asset—Unrecognized Tax Benefits	(46)		(46)
Total Amount of Unrecognized Tax Benefits that if Recognized, would Impact the Effective Tax Rate (including Interest and Penalties)	$	91	$	7

PSEG and its subsidiaries include accrued interest and penalties related to uncertain tax positions required to be recorded as Income Tax Expense in the Consolidated Statements of Operations. Accumulated interest and penalties that are recorded on the Consolidated Balance Sheets on uncertain tax positions were as follows:

	Accumulated Interest and Penalties on Uncertain Tax Positions as of December 31,
	2021		2020		2019
	Millions
PSEG	$	31	$	29	$	40
PSE&G	$	9	$	9	$	16

It is reasonably possible that total unrecognized tax benefits will significantly increase or decrease within the next twelve months due to either agreements with various taxing authorities upon audit, the expiration of the Statute of Limitations, or other pending tax matters. These potential increases or decreases are as follows:

Possible Decrease in Total Unrecognized Tax Benefits	Over the next 12 Months
	Millions
PSEG	$	25
PSE&G	$	15

A description of income tax years that remain subject to examination by material jurisdictions, where an examination has not already concluded are:

	PSEG	PSE&G
United States
Federal	2017-2020	N/A
New Jersey	2011-2020	2011-2020
Pennsylvania	2017-2020	2018-2020
Connecticut	2018-2020	N/A
Maryland	2018-2020	N/A
New York	2017-2020	N/A

New Jersey State Tax Reform

In September 2020, New Jersey enacted its State Fiscal Year 2021 Budget, which amended the temporary surtax originally enacted into law in 2018, from 1.5% to 2.5% for 2020 and 2021 and extended the 2.5% surtax to 2023. PSE&G continues to be exempt and this amendment will not have a material impact on PSEG’s and PSEG Power’s financial statements.

Public Service Electric and Gas Company

Income Taxes [Line Items]

Income Taxes

Income Taxes

A reconciliation of reported income tax expense for PSEG with the amount computed by multiplying pre-tax income by the statutory federal income tax rate of 21% is as follows:

	Years Ended December 31,
PSEG	2021			2020			2019
	Millions
Net Income (Loss)	$	(648)		$	1,905		$	1,693
Income Taxes:
Operating Income:
Current (Benefit) Expense:
Federal	$	407		$	385		$	84
State	(3)			48			18
Total Current	404			433			102
Deferred Expense (Benefit):
Federal	(700)			(164)			3
State	(136)			141			132
Total Deferred	(836)			(23)			135
ITC	(9)			(14)			20
Total Income Tax Expense (Benefit)	$	(441)		$	396		$	257
Pre-Tax Income (Loss)	$	(1,089)		$	2,301		$	1,950
Tax Computed at Statutory Rate @ 21%	$	(229)		$	483		$	410
Increase (Decrease) Attributable to Flow-Through of Certain Tax Adjustments:
State Income Taxes (net of federal income tax)	(109)			147			117
Uncertain Tax Positions	19			3			—
NDT Fund	23			32			34
Plant-Related Items	(7)			(9)			(2)
Tax Credits	29			(18)			(18)
Audit Settlement	(8)			(27)			—
Leasing Activities	(1)			(35)			—
GPRC-CEF-EE	(13)			—			—
TAC	(171)			(205)			(272)
Bad Debt Flow-Through	27			28			—
Other	(1)			(3)			(12)
Subtotal	(212)			(87)			(153)
Total Income Tax Expense (Benefit)	$	(441)		$	396		$	257
Effective Income Tax Rate	40.5		%	17.2		%	13.2		%

The following is an analysis of deferred income taxes for PSEG:

	As of December 31,
PSEG	2021		2020
	Millions
Deferred Income Taxes
Assets:
Noncurrent:
Regulatory Liability Excess Deferred Tax	$	439	$	485
OPEB	107		135
Bad Debt	67		40
Related to Uncertain Tax Positions	30		29
Interest Disallowance Carryforward	—		39
Operating Leases	48		60
Other	253		130
Total Noncurrent Assets	$	944	$	918
Liabilities:
Noncurrent:
Plant-Related Items	$	4,701	$	5,163
New Jersey Corporate Business Tax	939		1,016
Leasing Activities	113		133
AROs and NDT Fund	270		324
Taxes Recoverable Through Future Rates (net)	120		114
Pension Costs	169		97
Operating Leases	43		55
Other	271		247
Total Noncurrent Liabilities	$	6,626	$	7,149
Summary of Accumulated Deferred Income Taxes:
Net Noncurrent Deferred Income Tax Liabilities	$	5,682	$	6,231
ITC	77		271
Net Total Noncurrent Deferred Income Taxes and ITC	$	5,759	$	6,502

The deferred tax effect of certain assets and liabilities is presented in the table above net of the deferred tax effect associated with the respective regulatory deferrals.

A reconciliation of reported income tax expense for PSE&G with the amount computed by multiplying pre-tax income by the statutory federal income tax rate of 21% is as follows:

	Years Ended December 31,
PSE&G	2021			2020			2019
	Millions
Net Income	$	1,446		$	1,327		$	1,250
Income Taxes:
Operating Income:
Current (Benefit) Expense:
Federal	$	208		$	179		$	121
State	1			8			—
Total Current	209			187			121
Deferred Expense (Benefit):
Federal	(33)			(71)			(156)
State	153			128			117
Total Deferred	120			57			(39)
ITC	(5)			(4)			11
Total Income Tax Expense	$	324		$	240		$	93
Pre-Tax Income	$	1,770		$	1,567		$	1,343
Tax Computed at Statutory Rate @ 21%	$	372		$	329		$	282
Increase (Decrease) Attributable to Flow-Through of Certain Tax Adjustments:
State Income Taxes (net of federal income tax)	122			106			92
Uncertain Tax Positions	2			4			1
Plant-Related Items	(7)			(9)			(2)
Tax Credits	(8)			(9)			(8)
Audit Settlement	(1)			(2)			—
GPRC-CEF-EE	(13)			—			—
TAC	(171)			(205)			(272)
Bad Debt Flow-Through	27			28			—
Other	1			(2)			—
Subtotal	(48)			(89)			(189)
Total Income Tax Expense	$	324		$	240		$	93
Effective Income Tax Rate	18.3		%	15.3		%	6.9		%

The following is an analysis of deferred income taxes for PSE&G:

	As of December 31,
PSE&G	2021		2020
	Millions
Deferred Income Taxes
Assets:
Noncurrent:
Regulatory Liability Excess Deferred Tax	$	439	$	485
OPEB	61		82
Bad Debt	67		40
Operating Leases	20		21
Other	57		52
Total Noncurrent Assets	$	644	$	680
Liabilities:
Noncurrent:
Plant-Related Items	$	4,006	$	3,874
New Jersey Corporate Business Tax	863		721
Pension Costs	180		166
Taxes Recoverable Through Future Rates (net)	120		114
Conservation Costs	75		61
Operating Leases	19		21
Related to Uncertain Tax Positions	1		5
Other	178		161
Total Noncurrent Liabilities	$	5,442	$	5,123
Summary of Accumulated Deferred Income Taxes:
Net Noncurrent Deferred Income Tax Liabilities	$	4,798	$	4,443
ITC	76		81
Net Total Noncurrent Deferred Income Taxes and ITC	$	4,874	$	4,524

The deferred tax effect of certain assets and liabilities is presented in the table above net of the deferred tax effect associated with the respective regulatory deferrals.

PSEG and PSE&G each provide deferred taxes at the enacted statutory tax rate for all temporary differences between the financial statement carrying amounts and the tax bases of assets and liabilities irrespective of the treatment for rate-making purposes. Management believes that it is probable that the accumulated tax benefits that previously have been treated as a flow-through item to PSE&G customers will be recovered from or refunded to PSE&G’s customers in the future. See Note 7. Regulatory Assets and Liabilities.

The 2018 decrease in the federal tax rate resulted in PSE&G recording excess deferred income taxes. As of December 31, 2020, the balance was approximately $1.7 billion with a Regulatory Liability of approximately $2.4 billion. In 2021, PSE&G returned approximately $238 million of excess deferred income taxes and previously realized and current period deferred income taxes related to tax repair deductions to its customers with a reduction to tax expense of approximately $171 million. The flowback to customers of the excess deferred income taxes and previously realized tax repair deductions resulted in a decrease of approximately $215 million in the Regulatory Liability. The current period tax repair deduction reduces tax expense and revenue and recognizes a Regulatory Asset as PSE&G believes it is probable that the current period tax repair deductions flowed through to the customers will be recovered from customers in the future. See Note 7. Regulatory Assets and Liabilities for additional information.

In March 2020, the federal Coronavirus Aid, Relief, and Economic Security Act (CARES Act) was enacted. Among other provisions, the CARES Act allows a five-year carryback of any net operating loss (NOL) generated in a taxable year beginning after December 31, 2017, and before January 1, 2021.

In April 2020, the IRS issued a private letter ruling (PLR) to PSE&G concluding that certain excess deferred taxes previously classified as protected should be classified as unprotected. Unprotected excess deferred income taxes are not subject to the normalization rules allowing them to be refunded to customers sooner as agreed to with FERC and the BPU. In July 2020, FERC and the BPU approved PSE&G’s requests to refund these unprotected excess deferred income taxes to customers. FERC approved the refund of these unprotected excess deferred income taxes within the 2019 true-up filing. The BPU approved the refund of these unprotected excess deferred income taxes beginning in July 2020 through December 31, 2024.

In July 2020, the IRS issued final and proposed regulations addressing the limitation on deductible business interest expense contained in the Tax Act. These regulations retroactively allow depreciation to be added back in computing the 30% adjusted taxable income (ATI) cap, increasing the amount of interest that can be deducted by unregulated businesses in years before 2022. For 2022 and after, the regulations continue to disallow the addback of depreciation in the computation of ATI, effectively lowering the cap on the amount of deductible business interest and contain special rules in allocating interest between regulated and non-regulated businesses. The portion of PSEG’s and PSEG Power’s business interest expense that was disallowed in 2018 and 2019 under the previously issued proposed regulations will now be deductible in those respective years.

In March 2021, PSEG amended its 2018 federal income tax return to deduct the previously disallowed business interest expense in accordance with the final and proposed regulations issued in July 2020. The 2018 amended return generated a NOL that was carried back to 2013 as provided by the CARES Act.

PSEG expects that a prolonged economic recovery may result in additional federal or state tax legislation that can have a material impact on PSEG’s and PSE&G’s tax expense and cash tax position.

Amounts recorded under the Tax Act and CARES Act are subject to change based on several factors, including whether the IRS or state taxing authorities issue additional guidance and/or further clarification. Any further guidance or clarification could impact PSEG’s and PSE&G’s financial statements.

As of December 31, 2021, PSE&G had a $15 million New Jersey Corporate Business Tax NOL that is expected to be fully realized in the future. There are no other material tax carryforwards in other jurisdictions.

PSEG recorded the following amounts related to its unrecognized tax benefits, which were primarily comprised of amounts recorded for PSE&G and PSEG’s other subsidiaries:

2021	PSEG		PSE&G
	Millions
Total Amount of Unrecognized Tax Benefits as of January 1, 2021	$	147	$	30
Increases as a Result of Positions Taken in a Prior Period	58		8
Decreases as a Result of Positions Taken in a Prior Period	(19)		(12)
Increases as a Result of Positions Taken during the Current Period	6		1
Decreases as a Result of Positions Taken during the Current Period	—		—
Decreases as a Result of Settlements with Taxing Authorities	—		—
Decreases due to Lapses of Applicable Statute of Limitations	—		—
Total Amount of Unrecognized Tax Benefits as of December 31, 2021	$	192	$	27
Accumulated Deferred Income Taxes Associated with Unrecognized Tax Benefits	(76)		(15)
Regulatory Asset—Unrecognized Tax Benefits	(7)		(7)
Total Amount of Unrecognized Tax Benefits that if Recognized, would Impact the Effective Tax Rate (including Interest and Penalties)	$	109	$	5

2020	PSEG		PSE&G
	Millions
Total Amount of Unrecognized Tax Benefits as of January 1, 2020	$	321	$	124
Increases as a Result of Positions Taken in a Prior Period	33		21
Decreases as a Result of Positions Taken in a Prior Period	(91)		(51)
Increases as a Result of Positions Taken during the Current Period	—		—
Decreases as a Result of Positions Taken during the Current Period	—		—
Decreases as a Result of Settlements with Taxing Authorities	(116)		(64)
Decreases due to Lapses of Applicable Statute of Limitations	—		—
Total Amount of Unrecognized Tax Benefits as of December 31, 2020	$	147	$	30
Accumulated Deferred Income Taxes Associated with Unrecognized Tax Benefits	(69)		(12)
Regulatory Asset—Unrecognized Tax Benefits	(15)		(15)
Total Amount of Unrecognized Tax Benefits that if Recognized, would Impact the Effective Tax Rate (including Interest and Penalties)	$	63	$	3

In April 2020, the Joint Committee on Taxation approved PSEG’s nuclear carryback claim and federal tax returns for the years 2011 and 2012. In June 2020, the federal income tax audits for years 2011 through 2016 and the nuclear carryback claim were concluded.

2019	PSEG		PSE&G
	Millions
Total Amount of Unrecognized Tax Benefits as of January 1, 2019	$	318	$	108
Increases as a Result of Positions Taken in a Prior Period	17		5
Decreases as a Result of Positions Taken in a Prior Period	(37)		(1)
Increases as a Result of Positions Taken during the Current Period	27		12
Decreases as a Result of Positions Taken during the Current Period	—		—
Decreases as a Result of Settlements with Taxing Authorities	(4)		—
Decreases due to Lapses of Applicable Statute of Limitations	—		—
Total Amount of Unrecognized Tax Benefits as of December 31, 2019	$	321	$	124
Accumulated Deferred Income Taxes Associated with Unrecognized Tax Benefits	(184)		(71)
Regulatory Asset—Unrecognized Tax Benefits	(46)		(46)
Total Amount of Unrecognized Tax Benefits that if Recognized, would Impact the Effective Tax Rate (including Interest and Penalties)	$	91	$	7

PSEG and its subsidiaries include accrued interest and penalties related to uncertain tax positions required to be recorded as Income Tax Expense in the Consolidated Statements of Operations. Accumulated interest and penalties that are recorded on the Consolidated Balance Sheets on uncertain tax positions were as follows:

	Accumulated Interest and Penalties on Uncertain Tax Positions as of December 31,
	2021		2020		2019
	Millions
PSEG	$	31	$	29	$	40
PSE&G	$	9	$	9	$	16

It is reasonably possible that total unrecognized tax benefits will significantly increase or decrease within the next twelve months due to either agreements with various taxing authorities upon audit, the expiration of the Statute of Limitations, or other pending tax matters. These potential increases or decreases are as follows:

Possible Decrease in Total Unrecognized Tax Benefits	Over the next 12 Months
	Millions
PSEG	$	25
PSE&G	$	15

A description of income tax years that remain subject to examination by material jurisdictions, where an examination has not already concluded are:

	PSEG	PSE&G
United States
Federal	2017-2020	N/A
New Jersey	2011-2020	2011-2020
Pennsylvania	2017-2020	2018-2020
Connecticut	2018-2020	N/A
Maryland	2018-2020	N/A
New York	2017-2020	N/A

New Jersey State Tax Reform

In September 2020, New Jersey enacted its State Fiscal Year 2021 Budget, which amended the temporary surtax originally enacted into law in 2018, from 1.5% to 2.5% for 2020 and 2021 and extended the 2.5% surtax to 2023. PSE&G continues to be exempt and this amendment will not have a material impact on PSEG’s and PSEG Power’s financial statements.