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Income Taxes (All Registrants)
3 Months Ended
Mar. 31, 2024
Income Tax Disclosure [Abstract]  
Income Taxes (All Registrants) Income Taxes (All Registrants)
Rate Reconciliation
The effective income tax rate from continuing operations varies from the U.S. federal statutory rate principally due to the following:
Three Months Ended March 31, 2024(a)
Exelon
ComEd(b)
PECO(c)
BGE(b)
PHIPepcoDPLACE
U.S. Federal statutory rate21.0 %21.0 %21.0 %21.0 %21.0 %21.0 %21.0 %21.0 %
Increase (decrease) due to:
State income taxes, net of federal income tax benefit
6.4 7.8 (0.6)6.3 6.4 6.2 6.2 7.1 
Plant basis differences(3.8)(0.9)(12.2)(1.2)(0.9)(1.3)(1.1)0.1 
Excess deferred tax amortization(14.7)(18.9)(2.3)(17.5)(6.8)(9.9)(5.4)(1.3)
Amortization of investment tax credit, including deferred taxes on basis difference(0.1)(0.1)— — (0.1)— (0.1)(0.1)
Tax credits(0.4)(0.3)— (0.4)(0.3)(0.3)(0.3)(0.3)
Other0.3 0.4 0.4 0.1 (0.1)— 0.2 1.0 
Effective income tax rate8.7 %9.0 %6.3 %8.3 %19.2 %15.7 %20.5 %27.5 %
Three Months Ended March 31, 2023(a)
Exelon
ComEd
PECO(c)
BGE
PHI
Pepco
DPL
ACE
U.S. Federal statutory rate21.0 %21.0 %21.0 %21.0 %21.0 %21.0 %21.0 %21.0 %
Increase (decrease) due to:
State income taxes, net of federal income tax benefit
6.0 7.9 (1.4)6.4 6.0 5.4 6.3 6.9 
Plant basis differences(4.0)(0.3)(15.2)(0.7)(1.8)(2.5)(1.0)(0.9)
Excess deferred tax amortization(6.3)(5.7)(2.4)(5.4)(7.0)(8.4)(8.8)(2.0)
Amortization of investment tax credit, including deferred taxes on basis difference(0.1)(0.1)— (0.1)(0.1)— (0.1)(0.1)
Tax credits(0.5)(0.3)— (0.5)(0.4)(0.4)(0.4)(0.3)
Other
0.6 0.3 0.4 (0.1)0.3 0.5 (0.3)0.4 
Effective income tax rate16.7 %22.8 %2.4 %20.6 %18.0 %15.6 %16.7 %25.0 %
__________
(a)Positive percentages represent income tax expense. Negative percentages represent income tax benefit.
(b)For ComEd, the lower effective tax rate is primarily due to CEJA which resulted in the acceleration of certain income tax benefits. For BGE, the lower effective tax rate is primarily due to the Maryland multi-year plan which resulted in the acceleration of certain income tax benefits.
(c)For PECO, the lower effective tax rate is primarily related to plant basis differences attributable to tax repair deductions.
Unrecognized Tax Benefits
Exelon, PHI and ACE have the following unrecognized tax benefits at March 31, 2024 and December 31, 2023. ComEd's, PECO's, BGE's, Pepco's, and DPL's amounts are not material.
Exelon(a)
PHIACE
March 31, 2024$95 $51 $15 
December 31, 202394 51 15 
__________
(a)At March 31, 2024 and December 31, 2023, Exelon's unrecognized tax benefits is inclusive of $31 million related to Constellation's share of unrecognized tax benefits for periods prior to the separation. Exelon reflected an offsetting receivable of $31 million in Other deferred debits and other assets in the Consolidated Balance Sheet for these amounts.
Other Tax Matters
Tax Matters Agreement (Exelon)
In connection with the separation, Exelon entered into a TMA with Constellation. The TMA governs the respective rights, responsibilities, and obligations between Exelon and Constellation after the separation with respect to tax liabilities, refunds and attributes for open tax years that Constellation was part of Exelon’s consolidated group for U.S. federal, state, and local tax purposes.
Indemnification for Taxes. As a former subsidiary of Exelon, Constellation has joint and several liability with Exelon to the IRS and certain state jurisdictions relating to the taxable periods prior to the separation. The TMA specifies that Constellation is liable for their share of taxes required to be paid by Exelon with respect to taxable periods prior to the separation to the extent Constellation would have been responsible for such taxes under the existing Exelon tax sharing agreement.
Tax Refunds. The TMA specifies that Constellation is entitled to their share of any future tax refunds claimed by Exelon with respect to taxable periods prior to the separation to the extent that Constellation would have received such tax refunds under the existing Exelon tax sharing agreement.
Tax Attributes. At the date of separation certain tax attributes, primarily pre-closing tax credit carryforwards, that were generated by Constellation were required by law to be allocated to Exelon. The TMA provides that Exelon will reimburse Constellation when those allocated tax credit carryforwards are utilized. As of March 31, 2024, Exelon recorded a payable of $183 million and $331 million in Other current liabilities and Other deferred credits and other liabilities, respectively, in the Consolidated Balance Sheet for tax attribute carryforwards that are expected to be utilized and reimbursed to Constellation.
Corporate Alternative Minimum Tax (All Registrants)
On August 16, 2022, the IRA was signed into law and implements a new corporate alternative minimum tax (CAMT) that imposes a 15.0% tax on modified GAAP net income. Corporations are entitled to a tax credit (minimum tax credit) to the extent the CAMT liability exceeds the regular tax liability. This amount can be carried forward indefinitely and used in future years when regular tax exceeds the CAMT.
Beginning in 2023, based on the existing statue, Exelon and each of the Utility Registrants will be subject to and will report the CAMT on a separate Registrant basis in the Consolidated Statements of Operations and Comprehensive Income and the Consolidated Balance Sheets. The deferred tax asset related to the minimum tax credit carryforward will be realized to the extent Exelon’s consolidated deferred tax liabilities exceed the minimum tax credit carryforward. Exelon’s deferred tax liabilities are expected to exceed the minimum tax credit carryforward for the foreseeable future and thus no valuation allowance is required. Exelon is continuing to assess the financial statement impacts of the IRA and will update estimates based on future guidance issued by the U.S. Treasury.