The following table provides the components of Income from continuing operations before provision/(benefit) for taxes on income: | ||||||||||||
Year Ended December 31, | ||||||||||||
(MILLIONS OF DOLLARS) | 2017 | 2016 | 2015 | |||||||||
United States | $ | (6,879 | ) | $ | (8,534 | ) | $ | (6,809 | ) | |||
International | 19,184 | 16,886 | 15,773 | |||||||||
Income from continuing operations before provision/(benefit) for taxes on income(a), (b) | $ | 12,305 | $ | 8,351 | $ | 8,965 | ||||||
(a) | 2017 v. 2016––The decrease in the domestic loss was primarily due to lower restructuring charges and certain acquisition-related costs, the non-recurrence of the 2016 impairment on the remeasurement of HIS net assets, lower certain asset impairments and lower certain legal matters, partially offset by higher net losses on early retirement of debt, and higher amortization of intangible assets. The increase in international income was primarily due to the non-recurrence of the 2016 impairment on the remeasurement of HIS net assets, lower restructuring charges and certain acquisition-related costs, and lower certain asset impairments. |
(b) | 2016 v. 2015––The increase in the domestic loss was primarily due to a charge related to the write-down of HIS net assets to fair value less estimated costs to sell, higher asset impairments, and higher restructuring charges and certain acquisition-related costs, partially offset by the inclusion of a full year of legacy U.S. Hospira operations as compared to four months of U.S. operations in 2015, and lower charges for legal matters. The increase in international income is primarily due to the non-recurrence of a foreign currency loss related to Venezuela partially offset by a charge related to the write-down of HIS net assets to fair value less estimated costs to sell, and higher restructuring charges and certain acquisition-related costs. |
The following table provides the components of Provision/(benefit) for taxes on income based on the location of the taxing authorities: | ||||||||||||
Year Ended December 31, | ||||||||||||
(MILLIONS OF DOLLARS) | 2017 | 2016 | 2015 | |||||||||
United States | ||||||||||||
Current income taxes: | ||||||||||||
Federal | $ | 14,127 | $ | 342 | $ | 67 | ||||||
State and local | 320 | (52 | ) | (8 | ) | |||||||
Deferred income taxes: | ||||||||||||
Federal | (25,964 | ) | (419 | ) | 300 | |||||||
State and local | (268 | ) | (106 | ) | (36 | ) | ||||||
Total U.S. tax provision | (11,785 | ) | (235 | ) | 323 | |||||||
International | ||||||||||||
Current income taxes | 2,709 | 1,532 | 1,951 | |||||||||
Deferred income taxes | 28 | (175 | ) | (284 | ) | |||||||
Total international tax provision | 2,737 | 1,358 | 1,667 | |||||||||
Provision/(benefit) for taxes on income | $ | (9,049 | ) | $ | 1,123 | $ | 1,990 | |||||
• | estimated U.S. net tax benefits of $10.7 billion associated with the enactment of the TCJA (see discussion above), primarily reflecting: |
◦ | $22.8 billion tax benefit associated with the remeasurement of U.S. deferred tax liabilities on unremitted earnings of foreign subsidiaries (see Note 5C); |
◦ | $1.6 billion tax benefit associated with the remeasurement of other U.S. deferred tax liabilities, primarily associated with intangibles (see Note 5C); |
◦ | $12.9 billion tax expense related to the repatriation tax on deemed repatriated accumulated pre-2017 post-1986 earnings of foreign subsidiaries; |
◦ | $1.0 billion tax expense related to future taxes on global intangible low-taxed income (see Note 5C); and |
◦ | approximately $100 million tax benefit primarily associated with certain tax initiatives; |
• | U.S. tax expense of approximately $1.3 billion related to the repatriation tax on deemed repatriated current year earnings of foreign subsidiaries; |
• | tax benefit of approximately $370 million related to net losses on early retirement of debt; |
• | tax benefits of approximately $150 million representing tax and interest resulting from the resolution of certain tax positions pertaining to prior years primarily with various foreign tax authorities, and the expiration of certain statutes of limitations; and |
• | the non-deductibility of a $307 million fee payable to the federal government as a result of the U.S. Healthcare Legislation. |
• | U.S. tax expense of approximately $1.1 billion as a result of providing U.S. deferred income taxes on certain funds earned outside the U.S. that will not be indefinitely reinvested overseas, virtually all of which were earned in 2016 (see Note 5C); |
• | tax benefits of approximately $460 million, representing tax and interest, resulting from the resolution of certain tax positions pertaining to prior years, primarily with various foreign tax authorities, and from the expiration of certain statutes of limitations; |
• | benefits related to the final resolution of an agreement in principle reached in February 2016 and finalized in April 2016 to resolve certain claims related to Protonix, which resulted in the receipt of information that raised our initial assessment in 2015 of the likelihood of prevailing on the technical merits of our tax position; |
• | net tax benefits of $89 million, related to the adoption of a new accounting standard in the fourth quarter of 2016, as of January 1, 2016, requiring excess tax benefits or deficiencies of share-based compensation to be recognized as a component of the Provision/(benefit) for taxes on income (see Notes to Consolidated Financial Statements––Note 1B. Basis of Presentation and Significant Accounting Policies: Adoption of New Accounting Standards in Pfizer’s 2016 Financial Report); |
• | the non-deductibility of a $312 million fee payable to the federal government as a result of the U.S. Healthcare Legislation; and |
• | the permanent extension of the U.S. R&D tax credit, which was signed into law in December 2015. |
• | U.S. tax expense of approximately $2.1 billion as a result of providing U.S. deferred income taxes on certain funds earned outside the U.S. that will not be indefinitely reinvested overseas, virtually all of which were earned in 2015 (see Note 5C); |
• | tax benefits of approximately $360 million, representing tax and interest, resulting from the resolution of certain tax positions pertaining to prior years, primarily with various foreign tax authorities, and from the expiration of certain statutes of limitations; |
• | the permanent extension of the U.S. R&D tax credit, which was signed into law in December 2015, as well as tax benefits associated with certain tax initiatives; |
• | the non-deductibility of a foreign currency loss related to Venezuela; |
• | the non-deductibility of a charge for the agreement in principle reached in February 2016 to resolve claims relating to Protonix; and |
• | the non-deductibility of a $251 million fee payable to the federal government as a result of the U.S. Healthcare Legislation. |
The reconciliation of the U.S. statutory income tax rate to our effective tax rate for Income from continuing operations follows: | |||||||||
Year Ended December 31, | |||||||||
2017 | 2016 | 2015 | |||||||
U.S. statutory income tax rate | 35.0 | % | 35.0 | % | 35.0 | % | |||
TCJA impact(a) | (86.6 | ) | — | — | |||||
Taxation of non-U.S. operations (b), (c), (d) | (17.0 | ) | (13.8 | ) | (9.6 | ) | |||
Tax settlements and resolution of certain tax positions(e) | (1.2 | ) | (5.5 | ) | (4.0 | ) | |||
U.S. Healthcare Legislation(e) | 0.9 | 1.3 | 0.9 | ||||||
U.S. R&D tax credit and manufacturing deduction(e) | (0.7 | ) | (1.0 | ) | (1.0 | ) | |||
Certain legal settlements and charges(e) | 0.1 | (2.9 | ) | 3.1 | |||||
All other, net(f) | (3.9 | ) | 0.3 | (2.1 | ) | ||||
Effective tax rate for income from continuing operations | (73.5 | )% | 13.4 | % | 22.2 | % | |||
(a) | For a discussion about the enactment of the TCJA, see Note 5A. |
(b) | For taxation of non-U.S. operations, this rate impact reflects the income tax rates and relative earnings in the locations where we do business outside the U.S., together with the cost of repatriation decisions, which includes the repatriation tax on deemed repatriated current year earnings of foreign subsidiaries discussed in Note 5A, as well as changes in uncertain tax positions not included in the reconciling item called “Tax settlements and resolution of certain tax positions”. Specifically: (i) the jurisdictional location of earnings is a significant component of our effective tax rate each year as tax rates outside the U.S. are generally lower than the U.S. statutory income tax rate, and the rate impact of this component is influenced by the specific location of non-U.S. earnings and the level of such earnings as compared to our total earnings; (ii) the cost of repatriation decisions, and other U.S. tax implications of our foreign operations, is a significant component of our effective tax rate each year and generally offsets some of the reduction to our effective tax rate each year resulting from the jurisdictional location of earnings; and (iii) the impact of changes in uncertain tax positions not included in the reconciling item called “Tax settlements and resolution of certain tax positions” is a component of our effective tax rate each year that can result in either an increase or decrease to our effective tax rate. The jurisdictional mix of earnings, which includes the impact of the location of earnings as well as repatriation costs, can vary as a result of the repatriation decisions, as a result of operating fluctuations in the normal course of business and as a result of the extent and location of other income and expense items, such as restructuring charges, asset impairments and gains and losses on strategic business decisions. See also Note 5A for the components of pre-tax income and Provision/(benefit) for taxes on income, which is based on the location of the taxing authorities, and for information about settlements and other items impacting Provision/(benefit) for taxes on income. |
(c) | In all periods presented, the reduction in our effective tax rate resulting from the jurisdictional location of earnings is largely due to generally lower tax rates, as well as manufacturing and other incentives associated with our subsidiaries in Puerto Rico and Singapore. 2015 and 2016 also include incentives in Costa Rica and the Dominican Republic related to the Hospira infusion systems business, which was sold to ICU Medical in February 2017. We benefit from a Puerto Rican incentive grant that expires in 2029. Under the grant, we are partially exempt from income, property and municipal taxes. In Singapore, we benefit from incentive tax rates effective through 2031 on income from manufacturing and other operations. |
(d) | The favorable rate impact in 2017 also reflects lower repatriation costs associated with estimated current year income of our foreign subsidiaries. The favorable rate impact in 2016 also includes the non-recurrence of the non-deductibility of a foreign currency loss related to Venezuela. The rate impact in 2015 also includes the non-deductibility of a foreign currency loss related to Venezuela. |
(e) | For a discussion about tax settlements and resolution of certain tax positions, the impact of U.S. Healthcare Legislation, the U.S. R&D tax credit and manufacturing deduction and the impact of certain legal settlements and charges, see Note 5A. |
(f) | All other, net in 2017 and 2015 primarily relates to tax benefits associated with certain tax initiatives in the normal course of business. |
The components of our deferred tax assets and liabilities, shown before jurisdictional netting, follow: | ||||||||||||||||
2017 Deferred Tax* | 2016 Deferred Tax | |||||||||||||||
(MILLIONS OF DOLLARS) | Assets | (Liabilities) | Assets | (Liabilities) | ||||||||||||
Prepaid/deferred items | $ | 1,588 | $ | (132 | ) | $ | 2,180 | $ | (68 | ) | ||||||
Inventories | 224 | (3 | ) | 366 | (47 | ) | ||||||||||
Intangible assets(a) | 685 | (9,269 | ) | 1,139 | (15,172 | ) | ||||||||||
Property, plant and equipment | 123 | (755 | ) | 92 | (982 | ) | ||||||||||
Employee benefits | 2,219 | (109 | ) | 3,356 | (74 | ) | ||||||||||
Restructurings and other charges | 226 | (8 | ) | 458 | (2 | ) | ||||||||||
Legal and product liability reserves | 459 | — | 650 | — | ||||||||||||
Net operating loss/tax credit carryforwards(b) | 4,502 | — | 2,957 | — | ||||||||||||
Unremitted earnings(a), (c) | — | (1,067 | ) | — | (23,108 | ) | ||||||||||
State and local tax adjustments | 218 | — | 301 | — | ||||||||||||
All other | 488 | (424 | ) | 306 | (503 | ) | ||||||||||
10,732 | (11,767 | ) | 11,806 | (39,956 | ) | |||||||||||
Valuation allowances | (2,203 | ) | — | (1,949 | ) | — | ||||||||||
Total deferred taxes | $ | 8,529 | $ | (11,767 | ) | $ | 9,857 | $ | (39,956 | ) | ||||||
Net deferred tax liability(d) | $ | (3,238 | ) | $ | (30,099 | ) | ||||||||||
* | 2017 reflects the estimated remeasurement of U.S. deferred tax assets and liabilities as the result of the enactment of the TCJA. For additional information, see Note 5A. |
(a) | The decrease in 2017 is primarily the result of the enactment of the TCJA, which includes the remeasurement of deferred tax liabilities primarily associated with intangible assets and unremitted earnings of foreign subsidiaries as well as amortization on intangible assets. For additional information, see Note 5A. |
(b) | The amounts in 2017 and 2016 are reduced for unrecognized tax benefits of $3.4 billion and $3.0 billion, respectively, where we have net operating loss carryforwards, similar tax losses, and/or tax credit carryforwards that are available, under the tax law of the applicable jurisdiction, to settle any additional income taxes that would result from the disallowance of a tax position. |
(c) | The amount in 2017 primarily includes a provisional estimate on temporary differences associated with global intangible low-taxed income primarily related to basis differentials on intangibles. For additional information, see Note 5A. |
(d) | In 2017, Noncurrent deferred tax assets and other noncurrent tax assets ($0.7 billion), and Noncurrent deferred tax liabilities ($3.9 billion). In 2016, Noncurrent deferred tax assets and other noncurrent tax assets ($654 million), and Noncurrent deferred tax liabilities ($30.8 billion). |
• | Tax assets associated with uncertain tax positions primarily represent our estimate of the potential tax benefits in one tax jurisdiction that could result from the payment of income taxes in another tax jurisdiction. These potential benefits generally result from cooperative efforts among taxing authorities, as required by tax treaties to minimize double taxation, commonly referred to as the competent authority process. The recoverability of these assets, which we believe to be more likely than not, is dependent upon the actual payment of taxes in one tax jurisdiction and, in some cases, the successful petition for recovery in another tax jurisdiction. As of December 31, 2017 and 2016, we had approximately $1.2 billion, in each year, in assets associated with uncertain tax positions. In 2017, these amounts were included in Noncurrent deferred tax assets and other noncurrent tax assets ($1.0 billion) and Noncurrent deferred tax liabilities ($118 million). In 2016, these amounts were included in Noncurrent deferred tax assets and other noncurrent tax assets ($1.0 billion) and Noncurrent deferred tax liabilities ($201 million). |
• | Tax liabilities associated with uncertain tax positions represent unrecognized tax benefits, which arise when the estimated benefit recorded in our financial statements differs from the amounts taken or expected to be taken in a tax return because of the uncertainties described above. These unrecognized tax benefits relate primarily to issues common among multinational corporations. Substantially all of these unrecognized tax benefits, if recognized, would impact our effective income tax rate. |
The reconciliation of the beginning and ending amounts of gross unrecognized tax benefits follows: | ||||||||||||
(MILLIONS OF DOLLARS) | 2017 | 2016 | 2015 | |||||||||
Balance, beginning | $ | (5,826 | ) | $ | (5,919 | ) | $ | (6,182 | ) | |||
Acquisitions(a) | 10 | (83 | ) | (110 | ) | |||||||
Increases based on tax positions taken during a prior period(b) | (49 | ) | (11 | ) | (31 | ) | ||||||
Decreases based on tax positions taken during a prior period(b), (c) | 28 | 409 | 496 | |||||||||
Decreases based on settlements for a prior period(d) | 35 | 126 | 64 | |||||||||
Increases based on tax positions taken during the current period(b) | (753 | ) | (489 | ) | (675 | ) | ||||||
Impact of foreign exchange | (121 | ) | (5 | ) | 319 | |||||||
Other, net(b), (e) | 118 | 146 | 199 | |||||||||
Balance, ending(f) | $ | (6,558 | ) | $ | (5,826 | ) | $ | (5,919 | ) | |||
(a) | For 2017 and 2016, primarily related to the acquisitions of Medivation and Anacor. For 2015, primarily related to the acquisition of Hospira. See also Note 2A. |
(b) | Primarily included in Provision/(benefit) for taxes on income. |
(c) | Primarily related to effectively settling certain tax positions primarily with foreign tax authorities. See also Note 5A. |
(d) | Primarily related to cash payments and reductions of tax attributes. |
(e) | Primarily related to decreases as a result of a lapse of applicable statutes of limitations. |
(f) | In 2017, included in Income taxes payable ($1 million), Noncurrent deferred tax assets and other noncurrent tax assets ($123 million), Noncurrent deferred tax liabilities ($3.3 billion) and Other taxes payable ($3.2 billion). In 2016, included in Income taxes payable ($14 million), Current tax assets ($17 million), Noncurrent deferred tax assets and other noncurrent tax assets ($184 million), Noncurrent deferred tax liabilities ($2.8 billion) and Other taxes payable ($2.8 billion). |
• | Interest related to our unrecognized tax benefits is recorded in accordance with the laws of each jurisdiction and is recorded primarily in Provision/(benefit) for taxes on income in our consolidated statements of income. In 2017, we recorded a net increase in interest of $208 million. In 2016, we recorded a net increase in interest of $72 million; and in 2015, we recorded a net increase in interest of $71 million. Gross accrued interest totaled $975 million as of December 31, 2017 (reflecting a decrease of approximately $4 million as a result of cash payments) and gross accrued interest totaled $771 million as of December 31, 2016 (reflecting a decrease of approximately $18 million as a result of cash payments). In 2017, this amount was included in Other taxes payable ($975 million). In 2016, these amounts were included in Income taxes payable ($4 million), Current tax assets ($13 million) and Other taxes payable ($754 million). Accrued penalties are not significant. See also Note 5A. |
• | With respect to Pfizer, the IRS has issued a Revenue Agent’s Report (RAR) for tax years 2009-2010. We are not in agreement with the RAR and are currently appealing certain disputed issues. Tax years 2011-2013 are currently under audit. Tax years 2014-2017 are open, but not under audit. All other tax years are closed. |
• | With respect to Hospira, the federal income tax audit of tax years 2012-2013 was effectively settled in the third quarter of 2017. The IRS is currently auditing tax year 2014 through short-year 2015. All other tax years are closed. The tax years under audit for Hospira are not considered material to Pfizer. |
• | With respect to Anacor and Medivation, the open tax years are not considered material to Pfizer. |
The following table provides the components of the Tax provision/(benefit) on other comprehensive income/(loss): | ||||||||||||
Year Ended December 31, | ||||||||||||
(MILLIONS OF DOLLARS) | 2017 | 2016 | 2015 | |||||||||
Foreign currency translation adjustments, net(a) | $ | (215 | ) | $ | (15 | ) | $ | 90 | ||||
Unrealized holding gains/(losses) on derivative financial instruments, net | 72 | (75 | ) | (173 | ) | |||||||
Reclassification adjustments for (gains)/losses included in net income | (224 | ) | 158 | 104 | ||||||||
(152 | ) | 83 | (69 | ) | ||||||||
Unrealized holding gains/(losses) on available-for-sale securities, net | 102 | 49 | (104 | ) | ||||||||
Reclassification adjustments for (gains)/losses included in net income | (60 | ) | (15 | ) | 59 | |||||||
42 | 34 | (45 | ) | |||||||||
Benefit plans: actuarial losses, net | (59 | ) | (535 | ) | (23 | ) | ||||||
Reclassification adjustments related to amortization | 192 | 186 | 183 | |||||||||
Reclassification adjustments related to settlements, net | 42 | 45 | 237 | |||||||||
Other | (39 | ) | 36 | 66 | ||||||||
137 | (269 | ) | 462 | |||||||||
Benefit plans: prior service (costs)/credits and other, net | — | 67 | 160 | |||||||||
Reclassification adjustments related to amortization | (67 | ) | (64 | ) | (59 | ) | ||||||
Reclassification adjustments related to curtailments, net | (7 | ) | (10 | ) | (12 | ) | ||||||
Other | — | (1 | ) | — | ||||||||
(74 | ) | (7 | ) | 89 | ||||||||
Tax provision/(benefit) on other comprehensive income/(loss) | $ | (262 | ) | $ | (174 | ) | $ | 528 | ||||
(a) | Taxes are not provided for foreign currency translation adjustments relating to investments in international subsidiaries that will be held indefinitely. |