ComEd 2015 Annual Report Download - page 360

Table of Contents
Combined Notes to Consolidated Financial Statements—(Continued)
(Dollars in millions, except per share data unless otherwise noted)
$120 million of unrecognized tax benefits at December 31, 2015 that, if recognized, may be included in future base rates and that portion would
have no impact to the effective tax rate. Exelon and Generation had $701 million and $672 million, respectively, of unrecognized tax benefits at
December 31, 2014 that, if recognized, would decrease the effective tax rate. In 2015, the unrecognized tax benefits decreased at Exelon and
Generation due to settlements with state tax authorities and the expiration of statues of limitations for certain state jurisdictions.
Reasonably possible that total amount of unrecognized tax benefits could significantly increase or decrease within 12 months after
the reporting date

As of December 31, 2015, Exelon and ComEd have approximately $397 million and $142 million of unrecognized tax benefits that could
significantly decrease within the 12 months after the reporting date as a result of a decision in the like-kind exchange litigation described below.
Exelon and ComEd have unrecognized tax benefits that, if recognized, would decrease Exelon’s effective tax rate by $69 million and increase
ComEd’s effective tax rate by $11 million.

As of December 31, 2015, Exelon, Generation, and BGE have approximately $174 million, $54 million, and $120 million of unrecognized
state tax benefits that could significantly decrease within the 12 months after the reporting date as a result of completing audits, potential
settlements, and expected statute of limitation expirations. Of the above unrecognized tax benefits, Exelon and Generation have $54 million that,
if recognized, would decrease the effective tax rate. The unrecognized tax benefit related to BGE, if recognized, may be included in future base
rates and that portion would have no impact to the effective tax rate.
Total amounts of interest and penalties recognized
The following table represents the net interest receivable (payable), including interest related to tax positions reflected in the Registrants’
Consolidated Balance Sheets.
Net interest receivable (payable) as of Exelon Generation ComEd PECO BGE
December 31, 2015 $ (288) $ 80 $ (210) $ 3 $ (1)
December 31, 2014 (310) 40 (203) 3 (1)
The following table sets forth the net interest expense, including interest related to tax positions, recognized in interest expense (income) in
other income and deductions in the Registrants’ Consolidated Statements of Operations and Comprehensive Income. The Registrants have not
accrued any material penalties with respect to uncertain tax positions.
Net interest expense (income) for the years ended Exelon Generation ComEd PECO BGE
December 31, 2015 $ (13) $ (31) $ 7 $— $—
December 31, 2014 (36) (50) 6 — 1
December 31, 2013 391 17 281 (1) —
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Source: BALTIMORE GAS & ELECTRIC CO, 10-K, February 10, 2016 Powered by Morningstar® Document Research℠
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