Income Taxes

9 Months Ended

Jun. 30, 2025

Income Tax Disclosure [Abstract]

Income Taxes

INCOME TAXES

Effective Tax Rate

For the nine months ended 30 June 2025, our consolidated income statements include an income tax benefit of $205.5 compared to an income tax expense of $406.5 for the prior year period. The tax benefit in fiscal year 2025 represents an effective tax rate of 36.6% on the pre-tax loss reported for the nine months ended 30 June 2025 compared to an effective rate of 17.5% for tax expense on the pre-tax income reported for the nine months ended 30 June 2024. The year-to-date rate in fiscal year 2025 was primarily impacted by a pre-tax charge of approximately $3 billion, which was primarily recorded during the second quarter. Our effective tax rate was 17.9% and 16.6% for the three months ended 30 June 2025 and 2024, respectively.

Our estimates related to the items discussed below reflect our best judgment based on information available as of 30 June 2025. The amount and timing of final settlement of these items may differ from our current estimates, which could impact our tax provision in future periods. Similarly, impacts recognized in future periods may impact period tax costs and benefits.

Business and Asset Actions

In fiscal year 2025, we recorded charges related to our decision to exit certain projects and other cost reduction measures as described in Note 4, Business and Asset Actions. These efforts resulted in a pre-tax charge of approximately $3 billion, which was primarily recorded during the second quarter. The related net tax benefit of $649.3 included a $22.5 cost for reserves established for uncertain tax positions related to the deductibility of business and asset actions incurred in foreign subsidiaries and a $15.2 cost primarily related to lower U.S. tax benefits for foreign-derived income. We also incurred a $41.8 increase in our valuation allowance related to tax benefits for foreign business and asset actions for which we could not recognize an income tax benefit.

Tax Reform Adjustment Related to Deemed Foreign Dividends

During the second quarter of fiscal year 2025, we recorded a $34.9 net income tax benefit related to our intent to file a refund claim after the review of several U.S. Tax Court cases regarding the U.S. taxation of deemed foreign dividends in the transition year of the Tax Cuts and Jobs Act (our fiscal year 2018). While we were not a party to these cases, the opinions resulted in a change to our intent to pursue a refund claim. The $34.9 income tax benefit is net of a $67.8 reserve for an uncertain tax position related to the calculation of the refund amount.

Tax on Repatriation of Foreign Earnings

During the second quarter of fiscal year 2025, we recorded a $31.4 cost related to estimated withholding taxes on foreign earnings we no longer intend to indefinitely reinvest. There were no other significant changes to our assumptions regarding the reinvestment of foreign earnings during the first nine months of fiscal year 2025.

Shareholder Activism-Related Costs

As further discussed in Note 19, Supplemental Information, we recorded costs of $86.3 during the first nine months of fiscal year 2025 related to a proxy contest that concluded in January. The net tax benefit associated with these costs was $14.6.

Cash Paid for Taxes, Net of Refunds

Income tax payments, net of refunds, were $856.1 and $502.2 for the nine months ended 30 June 2025 and 2024, respectively. The fiscal year 2025 amount included approximately $395 of tax payments related to the gain on the sale of our LNG business in September 2024.