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Income Taxes
12 Months Ended
Dec. 31, 2014
Income Taxes
INCOME TAXES

The details of our consolidated income taxes as reported are as follows:
 
Years Ended December 31,
 
2014
 
2013
 
2012
 
(in millions)
Federal:
 
 
 
 
 
Current
$
51

 
$
(45
)
 
$
(52
)
Deferred
796

 
676

 
698

Total Federal
847

 
631

 
646

 
 
 
 
 
 
State and Local:
 
 
 
 
 
Current
25

 
29

 
35

Deferred
70

 
24

 
(77
)
Total State and Local
95

 
53

 
(42
)
 
 
 
 
 
 
Income Tax Expense
$
942

 
$
684

 
$
604



The following is a reconciliation of our consolidated difference between the amount of federal income taxes computed by multiplying book income before income taxes by the federal statutory tax rate and the amount of income taxes reported:
 
Years Ended December 31,
 
2014
 
2013
 
2012
 
(in millions)
Net Income
$
1,638
 
 
$
1,484
 
 
$
1,262
 
Income Tax Expense
942
 
 
684
 
 
604
 
Pretax Income
$
2,580
 

$
2,168
 

$
1,866
 
 
 
 
 
 
 
Income Taxes on Pretax Income at Statutory Rate (35%)
$
903
 
 
$
759
 
 
$
653
 
Increase (Decrease) in Income Taxes resulting from the following items:
 
 
 
 
 
Depreciation
54
 
 
47
 
 
39
 
Investment Tax Credits, Net
(13
)
 
(14
)
 
(14
)
State and Local Income Taxes, Net
64
 
 
29
 
 
(33
)
Removal Costs
(24
)
 
(21
)
 
(18
)
AFUDC
(42
)
 
(31
)
 
(39
)
Valuation Allowance
(2
)
 
5
 
 
6
 
U.K. Windfall Tax
 
 
(80
)
 
15
 
Other
2
 
 
(10
)
 
(5
)
Income Tax Expense
$
942
 

$
684
 

$
604
 
 
 
 
 
 
 
Effective Income Tax Rate
36.5

%


31.5

%


32.4

%



The following table shows elements of the net deferred tax liability and significant temporary differences:
 
December 31,
 
2014
 
2013
 
(in millions)
Deferred Tax Assets
$
2,653

 
$
2,900

Deferred Tax Liabilities
(13,599
)
 
(13,088
)
Net Deferred Tax Liabilities
$
(10,946
)
 
$
(10,188
)
 
 
 
 
Property Related Temporary Differences
$
(7,968
)
 
$
(7,508
)
Amounts Due from Customers for Future Federal Income Taxes
(255
)
 
(273
)
Deferred State Income Taxes
(811
)
 
(765
)
Securitized Assets
(753
)
 
(870
)
Regulatory Assets
(694
)
 
(609
)
Deferred Income Taxes on Other Comprehensive Loss
60

 
66

Accrued Nuclear Decommissioning
(611
)
 
(554
)
Net Operating Loss Carryforward
47

 
233

Tax Credit Carryforward
144

 
109

Valuation Allowance
(56
)
 
(97
)
All Other, Net
(49
)
 
80

Net Deferred Tax Liabilities
$
(10,946
)
 
$
(10,188
)


AEP System Tax Allocation Agreement

We, along with our subsidiaries, file a consolidated federal income tax return.  The allocation of the AEP System’s current consolidated federal income tax to the AEP System companies allocates the benefit of current tax losses to the AEP System companies giving rise to such losses in determining their current tax expense.  The tax benefit of the Parent is allocated to our subsidiaries with taxable income.  With the exception of the loss of the Parent, the method of allocation reflects a separate return result for each company in the consolidated group.

Federal and State Income Tax Audit Status

We are no longer subject to U.S. federal examination for years before 2011.  The IRS examination of years 2011, 2012 and 2013 started in April 2014.  Although the outcome of tax audits is uncertain, in our opinion, adequate provisions for federal income taxes have been made for potential liabilities resulting from such matters.  In addition, we accrue interest on these uncertain tax positions.  We are not aware of any issues for open tax years that upon final resolution are expected to materially impact net income.

We, along with our subsidiaries, file income tax returns in various state, local and foreign jurisdictions.  These taxing authorities routinely examine our tax returns and we are currently under examination in several state and local jurisdictions.  However, it is possible that we have filed tax returns with positions that may be challenged by these tax authorities.  We believe that adequate provisions for income taxes have been made for potential liabilities resulting from such challenges and the ultimate resolution of these audits will not materially impact net income.  We are no longer subject to state, local or non-U.S. income tax examinations by tax authorities for years before 2009.

Net Income Tax Operating Loss Carryforward

In 2012 and 2011, we recognized federal net income tax operating losses of $366 million and $226 million, respectively, driven primarily by bonus depreciation, pension plan contributions and other book-versus-tax temporary differences.  As of December 31, 2013, we had $156 million of unrealized federal net operating loss carryforward tax benefits.  Federal taxable income was sufficient enough in 2014 that these remaining federal net income tax operating loss tax benefits were realized in full. We recognized deferred state and local income tax benefits in 2012 and 2011. The state net income tax operating loss carryforwards as of December 31, 2014 are indicated in the table below:
State
 
State Net Income
Tax Operating
Loss
Carryforward
 
Year of
Expiration
 
 
(in millions)
 
 
Louisiana
 
$
431

 
2029
Missouri
 
9

 
2034
Oklahoma
 
322

 
2034
Tennessee
 
3

 
2026
West Virginia
 
286

 
2032


We anticipate future taxable income will be sufficient to realize the remaining state net income tax operating loss tax benefits before the state carryforward expires for each state.

As of December 31, 2013 we had $121 million of uncertain tax positions netted against the federal net income tax operating loss carryforward tax benefits. Due to the utilization of the net operating loss carryforward in 2014, $69 million is presented as a non-current uncertain tax position. As of December 31, 2014, we have $52 million of uncertain tax positions netted against tax credit and alternative minimum tax carryforward tax benefits.

Tax Credit Carryforward

Federal and state net income tax operating losses sustained in 2012, 2011 and 2009, along with lower federal and state taxable income in 2010, resulted in unused federal and state income tax credits.  As of December 31, 2014, we have total federal tax credit carryforwards of $144 million and total state tax credit carryforwards of $22 million, not all of which are subject to an expiration date.  If these credits are not utilized, the federal general business tax credits of $74 million will expire in the years 2028 through 2033.

We anticipate future federal taxable income will be sufficient to realize the tax benefits of the federal tax credits before they expire unused.  

In November 2014, APCo received an order from the Virginia SCC for its 2014 Virginia Biennial Base Rate Case (see Note 4). As a result of the final determination pertaining to the ability to realize future tax benefits for certain state net income tax operating loss and credit carryforwards, we determined that APCo is subject to the Virginia Minimum Tax on electric suppliers and the Virginia State Income Tax is no longer applicable. As a result, we derecognized the related state income tax benefits, which had been subject to valuation allowances.

Valuation Allowance

We assess past results and future operations to estimate and evaluate available positive and negative evidence to evaluate whether sufficient future taxable income will be generated to use existing deferred tax assets.  The positive evidence we considered is the history of positive pretax income and the fact that the tax losses resulted from temporary differences that will reverse in future periods.  On the basis of the evaluation of all available positive and negative evidence, as of December 31, 2014, a valuation allowance of $56 million for an unrealized capital loss has been recorded in order to recognize only the portion of the deferred tax assets that, more likely than not, will be realized. The amount of the deferred tax assets realizable, however, could be adjusted if estimates of future taxable income during the carryforward period are materially impacted.
Uncertain Tax Positions

In May 2013, the U.S. Supreme Court decided that the U.K. Windfall Tax imposed upon U.K. electric companies privatized between 1984 and 1996 is a creditable tax for U.S. federal income tax purposes.  We filed protective claims asserting the creditability of the tax, dependent upon the outcome of the case.  As a result of the favorable U.S. Supreme Court decision, we recognized a tax benefit of $80 million, plus $43 million of pretax interest income in the second quarter of 2013.  The tax benefit and interest income resulted in an increase in net income of $108 million, but did not result in the receipt of cash as of December 31, 2014. Due to the timing of the IRS audit cycle, receipt of cash is not expected within the next 12 months.

We recognize interest accruals related to uncertain tax positions in interest income or expense, as applicable, and penalties in Other Operation expense in accordance with the accounting guidance for “Income Taxes.”

The following table shows amounts reported for interest expense, interest income and reversal of prior period interest expense:
 
Years Ended December 31,
 
2014
 
2013
 
2012
 
(in millions)
Interest Expense
$
3

 
$
1

 
$
11

Interest Income
1

 
51

 

Reversal of Prior Period Interest Expense
2

 

 
1



The following table shows balances for amounts accrued for the receipt of interest and the payment of interest and penalties:
 
December 31,
 
2014
 
2013
 
(in millions)
Accrual for Receipt of Interest
$
44

 
$
43

Accrual for Payment of Interest and Penalties
6

 
5



The reconciliations of the beginning and ending amounts of unrecognized tax benefits are as follows:
 
2014
 
2013
 
2012
 
(in millions)
Balance as of January 1,
$
175

 
$
267

 
$
168

Increase  Tax Positions Taken During a Prior Period
18

 

 
23

Decrease  Tax Positions Taken During a Prior Period
(1
)
 
(94
)
 
(16
)
Increase  Tax Positions Taken During the Current Year

 
2

 
121

Decrease  Tax Positions Taken During the Current Year

 

 

Decrease  Settlements with Taxing Authorities
(1
)
 

 
(25
)
Decrease  Lapse of the Applicable Statute of Limitations
(9
)
 

 
(4
)
Balance as of December 31,
$
182


$
175


$
267



The total amount of unrecognized tax benefits that, if recognized, would affect the effective tax rate is $97 million, $87 million and $149 million for 2014, 2013 and 2012, respectively.  We believe there will be no significant net increase or decrease in unrecognized tax benefits within 12 months of the reporting date.

Federal Tax Legislation

The American Taxpayer Relief Act of 2012 (the 2012 Act) was enacted in January 2013.  Included in the 2012 Act was a one-year extension of 50% bonus depreciation.  The 2012 Act also retroactively extended the life of research and development, employment and several energy tax credits, which expired at the end of 2011.  The enacted provisions did not materially impact net income or financial condition but did have a favorable impact on cash flows in 2013.

The Tax Increase Prevention Act of 2014 (the 2014 Act) was enacted in December 2014. Included in the 2014 Act was a one-year extension of the 50% bonus depreciation. The 2014 Act also retroactively extended the life of research and development, employment and several energy tax credits, which expired at the end of 2013. The enacted provisions did not materially impact net income or financial condition but will have a favorable impact on future cash flows.

Federal Tax Regulations

In 2013, the U.S. Treasury Department issued final and re-proposed regulations regarding the deduction and capitalization of expenditures related to tangible property, effective for the tax years beginning in 2014.  In addition, the IRS issued Revenue Procedures under the Industry Issue Resolutions program that provides specific guidance for the implementation of the regulations for the electric utility industry.  These final regulations did not materially impact net income, cash flows or financial condition.

State Tax Legislation

Legislation was passed by the state of Indiana in May 2011 enacting a phased reduction in corporate income tax rate from 8.5% to 6.5%.  The 8.5% Indiana corporate income tax rate will be reduced 0.5% each year beginning after June 30, 2012 with the final reduction occurring in years beginning after June 30, 2015.

In May 2011, Michigan repealed its Business Tax regime and replaced it with a traditional corporate net income tax rate of 6%, effective January 1, 2012.

During the third quarter of 2013, it was determined that the state of West Virginia had achieved certain minimum levels of shortfall reserve funds.  As a result, the West Virginia corporate income tax rate was reduced from 7% to 6.5% in 2014.  

The enacted provisions did not materially impact net income, cash flows or financial condition.
Appalachian Power Co [Member]  
Income Taxes
INCOME TAXES

The details of the Registrant Subsidiaries’ income taxes as reported are as follows:
Year Ended December 31, 2014
 
APCo
 
I&M
 
OPCo
 
PSO
 
SWEPCo
 
 
(in thousands)
Income Tax Expense (Credit):
 
 
 
 
 
 
 
 
 
 
Current
 
$
10,926

 
$
14,273

 
$
58,057

 
$
(24,349
)
 
$
(171,629
)
Deferred
 
144,651

 
70,225

 
74,391

 
74,756

 
239,426

Deferred Investment Tax Credits
 
(649
)
 
(4,877
)
 
(241
)
 
175

 
(1,377
)
Income Tax Expense
 
$
154,928

 
$
79,621

 
$
132,207

 
$
50,582

 
$
66,420

Year Ended December 31, 2013
 
APCo
 
I&M
 
OPCo
 
PSO
 
SWEPCo
 
 
(in thousands)
Income Tax Expense (Credit):
 
 
 
 
 
 
 
 
 
 
Current
 
$
58,441

 
$
(49,067
)
 
$
92,625

 
$
7,689

 
$
(10,866
)
Deferred
 
75,714

 
129,109

 
134,463

 
53,788

 
81,888

Deferred Investment Tax Credits
 
(1,220
)
 
(4,931
)
 
(1,418
)
 
4,408

 
(1,561
)
Income Tax Expense
 
$
132,935

 
$
75,111

 
$
225,670

 
$
65,885

 
$
69,461

Year Ended December 31, 2012
 
APCo
 
I&M
 
OPCo
 
PSO
 
SWEPCo
 
 
(in thousands)
Income Tax Expense (Credit):
 
 
 
 
 
 
 
 
 
 
Current
 
$
28,307

 
$
(9,221
)
 
$
100,447

 
$
18,634

 
$
(214,353
)
Deferred
 
138,460

 
53,067

 
45,685

 
48,916

 
260,761

Deferred Investment Tax Credits
 
(1,240
)
 
(4,502
)
 
(1,849
)
 
(856
)
 
(550
)
Income Tax Expense
 
$
165,527

 
$
39,344

 
$
144,283

 
$
66,694

 
$
45,858



Shown below for each Registrant Subsidiary is a reconciliation of the difference between the amounts of federal income taxes computed by multiplying book income before income taxes by the federal statutory tax rate and the amount of income taxes reported:
APCo
Years Ended December 31,
 
2014
 
2013
 
2012
 
(in thousands)
Net Income
$
215,415
 
 
$
193,211
 
 
$
257,503
 
Income Tax Expense
154,928
 
 
132,935
 
 
165,527
 
Pretax Income
$
370,343
 
 
$
326,146
 
 
$
423,030
 
 
 
 
 
 
 
Income Taxes on Pretax Income at Statutory Rate (35%)
$
129,620
 
 
$
114,151
 
 
$
148,061
 
Increase (Decrease) in Income Taxes Resulting from the Following Items:
 
 
 
 
 
Depreciation
23,527
 
 
20,286
 
 
20,424
 
Investment Tax Credits, Net
(649
)
 
(1,220
)
 
(1,240
)
State and Local Income Taxes, Net
6,531
 
 
2,707
 
 
3,175
 
Removal Costs
(6,844
)
 
(6,454
)
 
(6,641
)
AFUDC
(3,768
)
 
(1,420
)
 
(1,145
)
Valuation Allowance
(2,498
)
 
5,062
 
 
5,674
 
Other
9,009
 
 
(177
)
 
(2,781
)
Income Tax Expense
$
154,928
 
 
$
132,935
 
 
$
165,527
 
 
 
 
 
 
 
Effective Income Tax Rate
41.8

%

 
40.8

%

 
39.1

%

I&M
Years Ended December 31,
 
2014
 
2013
 
2012
 
(in thousands)
Net Income
$
155,647
 
 
$
177,504
 
 
$
118,457
 
Income Tax Expense
79,621
 
 
75,111
 
 
39,344
 
Pretax Income
$
235,268
 
 
$
252,615
 
 
$
157,801
 
 
 
 
 
 
 
Income Taxes on Pretax Income at Statutory Rate (35%)
$
82,344
 
 
$
88,415
 
 
$
55,230
 
Increase (Decrease) in Income Taxes Resulting from the Following Items:
 
 
 
 
 
Depreciation
12,885
 
 
10,057
 
 
8,659
 
Investment Tax Credits, Net
(4,877
)
 
(4,931
)
 
(4,502
)
State and Local Income Taxes, Net
7,668
 
 
(882
)
 
(1,559
)
Removal Costs
(11,272
)
 
(9,432
)
 
(5,490
)
AFUDC
(9,994
)
 
(10,555
)
 
(7,218
)
Other
2,867
 
 
2,439
 
 
(5,776
)
Income Tax Expense
$
79,621
 
 
$
75,111
 
 
$
39,344
 
 
 
 
 
 
 
Effective Income Tax Rate
33.8

%

 
29.7

%

 
24.9

%


OPCo
Years Ended December 31,
 
2014
 
2013
 
2012
 
(in thousands)
Net Income
$
216,422
 
 
$
409,980
 
 
$
343,534
 
Income Tax Expense
132,207
 
 
225,670
 
 
144,283
 
Pretax Income
$
348,629
 
 
$
635,650
 
 
$
487,817
 
 
 
 
 
 
 
Income Taxes on Pretax Income at Statutory Rate (35%)
$
122,020
 
 
$
222,478
 
 
$
170,736
 
Increase (Decrease) in Income Taxes Resulting from the Following Items:
 
 
 
 
 
Depreciation
6,665
 
 
6,759
 
 
5,239
 
Investment Tax Credits, Net
(241
)
 
(1,418
)
 
(1,849
)
State and Local Income Taxes, Net
8,866
 
 
3,327
 
 
(18,291
)
Parent Company Loss Benefit
(996
)
 
(2,154
)
 
(11,915
)
Other
(4,107
)
 
(3,322
)
 
363
 
Income Tax Expense
$
132,207
 
 
$
225,670
 
 
$
144,283
 
 
 
 
 
 
 
Effective Income Tax Rate
37.9

%

 
35.5

%

 
29.6

%


PSO
Years Ended December 31,
 
2014
 
2013
 
2012
 
(in thousands)
Net Income
$
86,929
 
 
$
97,796
 
 
$
114,141
 
Income Tax Expense
50,582
 
 
65,885
 
 
66,694
 
Pretax Income
$
137,511
 
 
$
163,681
 
 
$
180,835
 
 
 
 
 
 
 
Income Taxes on Pretax Income at Statutory Rate (35%)
$
48,129
 
 
$
57,288
 
 
$
63,292
 
Increase (Decrease) in Income Taxes Resulting from the Following Items:
 
 
 
 
 
Depreciation
176
 
 
164
 
 
(10
)
Investment Tax Credits, Net
(770
)
 
(776
)
 
(781
)
State and Local Income Taxes, Net
4,777
 
 
5,423
 
 
6,953
 
Tax Adjustments
(1,241
)
 
5,268
 
 
201
 
Other
(489
)
 
(1,482
)
 
(2,961
)
Income Tax Expense
$
50,582
 
 
$
65,885
 
 
$
66,694
 
 
 
 
 
 
 
Effective Income Tax Rate
36.8

%

 
40.3

%

 
36.9

%


SWEPCo
Years Ended December 31,
 
2014
 
2013
 
2012
 
(in thousands)
Net Income
$
144,559
 
 
$
153,819
 
 
$
202,513
 
Income Tax Expense
66,420
 
 
69,461
 
 
45,858
 
Pretax Income
$
210,979
 
 
$
223,280
 
 
$
248,371
 
 
 
 
 
 
 
Income Taxes on Pretax Income at Statutory Rate (35%)
$
73,843
 
 
$
78,148
 
 
$
86,930
 
Increase (Decrease) in Income Taxes Resulting from the Following Items:
 
 
 
 
 
Depreciation
2,944
 
 
3,086
 
 
2,105
 
Depletion
(4,143
)
 
(3,472
)
 
(3,276
)
Investment Tax Credits, Net
(1,377
)
 
(1,561
)
 
(550
)
State and Local Income Taxes, Net
3,083
 
 
(1,453
)
 
(18,010
)
AFUDC
(4,182
)
 
(2,381
)
 
(19,879
)
Other
(3,748
)
 
(2,906
)
 
(1,462
)
Income Tax Expense
$
66,420
 
 
$
69,461
 
 
$
45,858
 
 
 
 
 
 
 
Effective Income Tax Rate
31.5

%

 
31.1

%

 
18.5

%



The following tables show elements of the net deferred tax liability and significant temporary differences for each Registrant Subsidiary:
APCo
December 31,
 
2014
 
2013
 
(in thousands)
Deferred Tax Assets
$
446,346

 
$
548,966

Deferred Tax Liabilities
(2,711,233
)
 
(2,788,306
)
Net Deferred Tax Liabilities
$
(2,264,887
)
 
$
(2,239,340
)
 
 
 
 
Property Related Temporary Differences
$
(1,801,885
)
 
$
(1,725,853
)
Amounts Due from Customers for Future Federal Income Taxes
(70,417
)
 
(94,775
)
Deferred State Income Taxes
(239,724
)
 
(246,247
)
Regulatory Assets
(113,671
)
 
(104,824
)
Securitized Assets
(122,559
)
 
(130,834
)
Deferred Income Taxes on Other Comprehensive Loss
(2,710
)
 
(1,589
)
Net Operating Loss Carryforward
9,796

 
45,177

Tax Credit Carryforward
46,162

 
21,940

Valuation Allowance

 
(41,277
)
All Other, Net
30,121

 
38,942

Net Deferred Tax Liabilities
$
(2,264,887
)
 
$
(2,239,340
)

I&M
December 31,
 
2014
 
2013
 
(in thousands)
Deferred Tax Assets
$
911,811

 
$
843,630

Deferred Tax Liabilities
(2,190,002
)
 
(2,043,810
)
Net Deferred Tax Liabilities
$
(1,278,191
)
 
$
(1,200,180
)
 
 
 
 
Property Related Temporary Differences
$
(418,724
)
 
$
(390,829
)
Amounts Due from Customers for Future Federal Income Taxes
(40,580
)
 
(39,137
)
Deferred State Income Taxes
(138,907
)
 
(137,162
)
Deferred Income Taxes on Other Comprehensive Loss
7,732

 
8,351

Accrued Nuclear Decommissioning
(610,955
)
 
(553,794
)
Net Operating Loss Carryforward

 
15,690

Regulatory Assets
(74,690
)
 
(59,008
)
All Other, Net
(2,067
)
 
(44,291
)
Net Deferred Tax Liabilities
$
(1,278,191
)
 
$
(1,200,180
)

OPCo
December 31,
 
2014
 
2013
 
(in thousands)
Deferred Tax Assets
$
171,816

 
$
183,085

Deferred Tax Liabilities
(1,528,130
)
 
(1,477,691
)
Net Deferred Tax Liabilities
$
(1,356,314
)
 
$
(1,294,606
)
 
 
 
 
Property Related Temporary Differences
$
(926,520
)
 
$
(841,607
)
Amounts Due from Customers for Future Federal Income Taxes
(47,598
)
 
(51,946
)
Deferred State Income Taxes
(34,232
)
 
(28,569
)
Regulatory Assets
(242,391
)
 
(215,535
)
Deferred Income Taxes on Other Comprehensive Loss
(3,016
)
 
(3,812
)
Deferred Fuel and Purchased Power
(145,515
)
 
(176,192
)
All Other, Net
42,958

 
23,055

Net Deferred Tax Liabilities
$
(1,356,314
)
 
$
(1,294,606
)

PSO
December 31,
 
2014
 
2013
 
(in thousands)
Deferred Tax Assets
$
110,758

 
$
107,567

Deferred Tax Liabilities
(1,016,721
)
 
(936,791
)
Net Deferred Tax Liabilities
$
(905,963
)
 
$
(829,224
)
 
 
 
 
Property Related Temporary Differences
$
(805,193
)
 
$
(736,160
)
Amounts Due from Customers for Future Federal Income Taxes
(678
)
 
(31
)
Deferred State Income Taxes
(109,285
)
 
(99,126
)
Regulatory Assets
(39,620
)
 
(39,414
)
Deferred Income Taxes on Other Comprehensive Loss
(2,661
)
 
(3,100
)
Deferred Federal Income Taxes on Deferred State Income Taxes
43,918

 
40,362

Net Operating Loss Carryforward
6,365

 
4,314

Tax Credit Carryforward
681

 
565

All Other, Net
510

 
3,366

Net Deferred Tax Liabilities
$
(905,963
)
 
$
(829,224
)

SWEPCo
December 31,
 
2014
 
2013
 
(in thousands)
Deferred Tax Assets
$
186,176

 
$
359,529

Deferred Tax Liabilities
(1,528,246
)
 
(1,453,710
)
Net Deferred Tax Liabilities
$
(1,342,070
)
 
$
(1,094,181
)
 
 
 
 
Property Related Temporary Differences
$
(1,235,136
)
 
$
(1,172,431
)
Amounts Due from Customers for Future Federal Income Taxes
(44,119
)
 
(43,116
)
Deferred State Income Taxes
(124,147
)
 
(118,179
)
Regulatory Assets
(19,388
)
 
(5,290
)
Deferred Income Taxes on Other Comprehensive Loss
4,021

 
4,548

Impairment Loss - Turk Plant
21,052

 
21,295

Net Operating Loss Carryforward
21,925

 
189,128

All Other, Net
33,722

 
29,864

Net Deferred Tax Liabilities
$
(1,342,070
)
 
$
(1,094,181
)


AEP System Tax Allocation Agreement

The Registrant Subsidiaries join in the filing of a consolidated federal income tax return with their affiliates in the AEP System.  The allocation of the AEP System’s current consolidated federal income tax to the AEP System companies allocates the benefit of current tax losses to the AEP System companies giving rise to such losses in determining their current tax expense.  The tax benefit of the Parent is allocated to its subsidiaries with taxable income.  With the exception of the loss of the Parent, the method of allocation reflects a separate return result for each company in the consolidated group.

Federal and State Income Tax Audit Status

The Registrant Subsidiaries are no longer subject to U.S. federal examination for years before 2011.  The IRS examination of years 2011, 2012 and 2013 started in April 2014. Although the outcome of tax audits is uncertain, in management’s opinion, adequate provisions for federal income taxes have been made for potential liabilities resulting from such matters.  In addition, the Registrant Subsidiaries accrue interest on these uncertain tax positions.  Management is not aware of any issues for open tax years that upon final resolution are expected to materially impact net income.

The Registrant Subsidiaries file income tax returns in various state and local jurisdictions.  These taxing authorities routinely examine their tax returns and the Registrant Subsidiaries are currently under examination in several state and local jurisdictions.  However, it is possible that previously filed tax returns have positions that may be challenged by these tax authorities.  Management believes that adequate provisions for income taxes have been made for potential liabilities resulting from such challenges and that the ultimate resolution of these audits will not materially impact net income.  The Registrant Subsidiaries are no longer subject to state or local income tax examinations by tax authorities for years before 2009.

Net Income Tax Operating Loss Carryforward

In 2011, APCo and I&M recognized federal net income tax operating losses of $313 million and $123 million, respectively, driven primarily by bonus depreciation, pension plan contributions and other book versus tax temporary differences.  In 2012, SWEPCo recognized a federal net income tax operating loss of $858 million driven primarily by bonus depreciation.  APCo, OPCo, PSO and SWEPCo also have state net income tax operating loss carryforwards as indicated in the table below:
Company
 
State
 
State Net Income
Tax Operating
Loss
Carryforward
 
Year of
Expiration
 
 
 
 
(in thousands)
 
 
APCo
 
Tennessee
 
$
2,695

 
2026
APCo
 
West Virginia
 
235,341

 
2032
OPCo
 
West Virginia
 
50,228

 
2032
PSO
 
Oklahoma
 
163,212

 
2034
SWEPCo
 
Louisiana
 
419,384

 
2029
SWEPCo
 
Oklahoma
 
2,994

 
2034


As a result, APCo, OPCo, PSO and SWEPCo recognized deferred state and local income tax benefits in 2011, and/or 2012, and/or 2013 and/or 2014.  At the end of 2013, APCo, I&M and SWEPCo had $12 million, $13 million and $167 million, respectively, of unrealized federal net operating loss carryforward.  Federal taxable income was sufficient enough in 2014 that these remaining federal net income tax operating loss tax benefits were realized in full.  Management also anticipates future taxable income will be sufficient to realize the remaining state net income tax operating loss tax benefits before the state carryforward expires for each state.

Tax Credit Carryforward

Federal and state net income tax operating losses sustained in 2011 and 2009 along with lower federal and state taxable income in 2010 resulted in unused federal and state income tax credits.  As of December 31, 2014, the Registrant Subsidiaries have federal tax credit carryforwards and PSO has state tax credit carryforwards as indicated in the table below.  If these credits are not utilized, federal general business tax credits will expire in the years 2029 through 2033.
Company
 
Total Federal
Tax Credit
Carryforward
 
Federal Tax
Credit
Carryforward
Subject to
Expiration
 
Total State
Tax Credit
Carryforward
 
State Tax
Credit
Carryforward
Subject to
Expiration
 
 
(in thousands)
APCo
 
$
45,654

 
$
4,046

 
$

 
$

I&M
 
3,418

 
2,877

 

 

OPCo
 
25,679

 
1,962

 

 

PSO
 
681

 
660

 
22,141

 
22,141

SWEPCo
 
3,254

 
899

 

 



The Registrant Subsidiaries anticipate future federal taxable income will be sufficient to realize the tax benefits of the federal tax credits before they expire unused.  In November 2014, APCo received an order from the Virginia SCC for its 2014 Virginia Biennial Base Rate Case (see Note 4). As a result of the final determination pertaining to the ability to realize future tax benefits for certain state net income tax operating loss and credit carryforwards, management determined that APCo is subject to the Virginia Minimum Tax on electric suppliers and the Virginia State Income Tax is no longer applicable. As a result, management derecognized the related state income tax benefits, which had been subject to valuation allowances.

Uncertain Tax Positions

The Registrant Subsidiaries recognize interest accruals related to uncertain tax positions in interest income or expense as applicable and penalties in Other Operation expense in accordance with the accounting guidance for “Income Taxes.”

The following tables show amounts reported for interest expense, interest income and reversal of prior period interest expense:
 
 
Years Ended December 31,
 
 
2014
 
2013
Company
 
Interest
Expense
 
Interest
Income
 
Reversal of
Prior Period
Interest
Expense
 
Interest
Expense
 
Interest
Income
 
Reversal of
Prior Period
Interest
Expense
 
 
(in thousands)
APCo
 
$

 
$

 
$
193

 
$

 
$
1,089

 
$

I&M
 

 

 
289

 

 
597

 

OPCo
 
129

 

 
245

 

 
1,892

 

PSO
 
88

 

 
137

 

 
135

 

SWEPCo
 
172

 

 
154

 
215

 

 

 
 
Year Ended December 31, 2012
Company
 
Interest
Expense
 
Interest
Income
 
Reversal of
Prior Period
Interest
Expense
 
 
(in thousands)
APCo
 
$
62

 
$

 
$
183

I&M
 
1,355

 

 

OPCo
 
266

 

 
504

PSO
 
259

 

 
294

SWEPCo
 
286

 

 
271



The following table shows balances for amounts accrued for the receipt of interest:
 
 
December 31,
Company
 
2014
 
2013
 
 
(in thousands)
APCo
 
$

 
$

I&M
 

 

OPCo
 

 

PSO
 

 
209

SWEPCo
 

 
172



The following table shows balances for amounts accrued for the payment of interest and penalties:
 
 
December 31,
Company
 
2014
 
2013
 
 
(in thousands)
APCo
 
$

 
$
158

I&M
 
526

 
957

OPCo
 
382

 
407

PSO
 
310

 
562

SWEPCo
 
1,010

 
1,167



The reconciliations of the beginning and ending amounts of unrecognized tax benefits are as follows:
 
APCo
 
I&M
 
OPCo
 
PSO
 
SWEPCo
 
(in thousands)
Balance as of January 1, 2014
$
1,164

 
$
3,164

 
$
2,086

 
$
2,184

 
$
7,602

Increase  Tax Positions Taken During a Prior Period

 
1,431

 
6,335

 
64

 
1,602

Decrease  Tax Positions Taken During a Prior Period

 

 

 
(18
)
 
(832
)
Increase  Tax Positions Taken During the Current Year

 

 

 

 

Decrease  Tax Positions Taken During the Current Year

 

 

 

 

Increase  Settlements with Taxing Authorities
1

 

 
70

 
37

 

Decrease  Settlements with Taxing Authorities

 
(660
)
 

 

 
(30
)
Decrease  Lapse of the Applicable Statute of Limitations
(1,165
)
 
(1,640
)
 
(1,566
)
 
(948
)
 
(845
)
Balance as of December 31, 2014
$

 
$
2,295

 
$
6,925

 
$
1,319

 
$
7,497

 
APCo
 
I&M
 
OPCo
 
PSO
 
SWEPCo
 
(in thousands)
Balance as of January 1, 2013
$
5,253

 
$
15,085

 
$
11,052

 
$
2,273

 
$
9,553

Increase  Tax Positions Taken During a Prior Period

 

 

 

 

Decrease  Tax Positions Taken During a Prior Period
(4,089
)
 
(11,921
)
 
(8,966
)
 
(103
)
 
(3,158
)
Increase  Tax Positions Taken During the Current Year

 

 

 
14

 
1,301

Decrease  Tax Positions Taken During the Current Year

 

 

 

 

Decrease  Settlements with Taxing Authorities

 

 

 

 
(94
)
Decrease  Lapse of the Applicable Statute of Limitations

 

 

 

 

Balance as of December 31, 2013
$
1,164

 
$
3,164

 
$
2,086

 
$
2,184

 
$
7,602

 
APCo
 
I&M
 
OPCo
 
PSO
 
SWEPCo
 
(in thousands)
Balance as of January 1, 2012
$
7,311

 
$
14,071

 
$
43,565

 
$
3,585

 
$
9,031

Increase  Tax Positions Taken During a Prior Period

 
2,266

 
1,360

 
421

 
2,806

Decrease  Tax Positions Taken During a Prior Period
(384
)
 
(1,252
)
 
(13,582
)
 
(92
)
 
(775
)
Increase  Tax Positions Taken During the Current Year

 

 

 

 

Decrease  Tax Positions Taken During the Current Year

 

 

 

 

Decrease  Settlements with Taxing Authorities
(1,674
)
 

 
(20,291
)
 

 

Decrease  Lapse of the Applicable Statute of Limitations

 

 

 
(1,641
)
 
(1,509
)
Balance as of December 31, 2012
$
5,253

 
$
15,085

 
$
11,052

 
$
2,273

 
$
9,553



Management believes that there will be no significant net increase or decrease in unrecognized benefits within 12 months of the reporting date.  The total amount of unrecognized tax benefits that, if recognized, would affect the effective tax rate for each Registrant Subsidiary was as follows:
Company
 
2014
 
2013
 
2012
 
 
(in thousands)
APCo
 
$

 
$

 
$

I&M
 
1,591

 
1,220

 
1,220

OPCo
 
4,462

 
674

 
674

PSO
 
858

 
827

 
818

SWEPCo
 
4,873

 
4,357

 
3,512



Federal Tax Legislation – Affecting APCo, I&M, OPCo, PSO and SWEPCo

The American Taxpayer Relief Act of 2012 (the 2012 Act) was enacted in January 2013.  Included in the 2012 Act was a one-year extension of 50% bonus depreciation.  The 2012 Act also retroactively extended the life of research and development, employment and several energy tax credits, which expired at the end of 2011.  The enacted provisions did not materially impact the Registrant Subsidiaries’ net income or financial condition but did have a favorable impact on cash flows in 2013.

The Tax Increase Prevention Act of 2014 (the 2014 Act) was enacted in December 2014. Included in the 2014 Act was a one-year extension of the 50% bonus depreciation. The 2014 Act also retroactively extended the life of research and development, employment and several energy tax credits, which expired at the end of 2013. The enacted provisions did not materially impact the Registrant Subsidiaries' net income or financial condition but will have a favorable impact on future cash flows.

Federal Tax Regulations

In 2013, the U.S. Treasury Department issued final and re-proposed regulations regarding the deduction and capitalization of expenditures related to tangible property, effective for the tax years beginning in 2014.  In addition, the IRS issued Revenue Procedures under the Industry Issue Resolutions program that provides specific guidance for the implementation of the regulations for the electric utility industry.  These final regulations did not materially impact the Registrant Subsidiaries' net income, cash flows or financial condition.

State Tax Legislation – Affecting APCo, I&M and OPCo

Legislation was passed by the state of Indiana in May 2011 enacting a phased reduction in corporate income tax rate from 8.5% to 6.5%.  The 8.5% Indiana corporate income tax rate will be reduced 0.5% each year beginning after June 30, 2012 with the final reduction occurring in years beginning after June 30, 2015.

In May 2011, Michigan repealed its Business Tax regime and replaced it with a traditional corporate net income tax rate of 6%, effective January 1, 2012.

During the third quarter of 2013, it was determined that the state of West Virginia had achieved certain minimum levels of shortfall reserve funds.  As a result, the West Virginia corporate income tax rate was reduced from 7% to 6.5% in 2014.  

The enacted provisions did not materially impact the Registrant Subsidiaries’ net income, cash flows or financial condition.
Indiana Michigan Power Co [Member]  
Income Taxes
INCOME TAXES

The details of the Registrant Subsidiaries’ income taxes as reported are as follows:
Year Ended December 31, 2014
 
APCo
 
I&M
 
OPCo
 
PSO
 
SWEPCo
 
 
(in thousands)
Income Tax Expense (Credit):
 
 
 
 
 
 
 
 
 
 
Current
 
$
10,926

 
$
14,273

 
$
58,057

 
$
(24,349
)
 
$
(171,629
)
Deferred
 
144,651

 
70,225

 
74,391

 
74,756

 
239,426

Deferred Investment Tax Credits
 
(649
)
 
(4,877
)
 
(241
)
 
175

 
(1,377
)
Income Tax Expense
 
$
154,928

 
$
79,621

 
$
132,207

 
$
50,582

 
$
66,420

Year Ended December 31, 2013
 
APCo
 
I&M
 
OPCo
 
PSO
 
SWEPCo
 
 
(in thousands)
Income Tax Expense (Credit):
 
 
 
 
 
 
 
 
 
 
Current
 
$
58,441

 
$
(49,067
)
 
$
92,625

 
$
7,689

 
$
(10,866
)
Deferred
 
75,714

 
129,109

 
134,463

 
53,788

 
81,888

Deferred Investment Tax Credits
 
(1,220
)
 
(4,931
)
 
(1,418
)
 
4,408

 
(1,561
)
Income Tax Expense
 
$
132,935

 
$
75,111

 
$
225,670

 
$
65,885

 
$
69,461

Year Ended December 31, 2012
 
APCo
 
I&M
 
OPCo
 
PSO
 
SWEPCo
 
 
(in thousands)
Income Tax Expense (Credit):
 
 
 
 
 
 
 
 
 
 
Current
 
$
28,307

 
$
(9,221
)
 
$
100,447

 
$
18,634

 
$
(214,353
)
Deferred
 
138,460

 
53,067

 
45,685

 
48,916

 
260,761

Deferred Investment Tax Credits
 
(1,240
)
 
(4,502
)
 
(1,849
)
 
(856
)
 
(550
)
Income Tax Expense
 
$
165,527

 
$
39,344

 
$
144,283

 
$
66,694

 
$
45,858



Shown below for each Registrant Subsidiary is a reconciliation of the difference between the amounts of federal income taxes computed by multiplying book income before income taxes by the federal statutory tax rate and the amount of income taxes reported:
APCo
Years Ended December 31,
 
2014
 
2013
 
2012
 
(in thousands)
Net Income
$
215,415
 
 
$
193,211
 
 
$
257,503
 
Income Tax Expense
154,928
 
 
132,935
 
 
165,527
 
Pretax Income
$
370,343
 
 
$
326,146
 
 
$
423,030
 
 
 
 
 
 
 
Income Taxes on Pretax Income at Statutory Rate (35%)
$
129,620
 
 
$
114,151
 
 
$
148,061
 
Increase (Decrease) in Income Taxes Resulting from the Following Items:
 
 
 
 
 
Depreciation
23,527
 
 
20,286
 
 
20,424
 
Investment Tax Credits, Net
(649
)
 
(1,220
)
 
(1,240
)
State and Local Income Taxes, Net
6,531
 
 
2,707
 
 
3,175
 
Removal Costs
(6,844
)
 
(6,454
)
 
(6,641
)
AFUDC
(3,768
)
 
(1,420
)
 
(1,145
)
Valuation Allowance
(2,498
)
 
5,062
 
 
5,674
 
Other
9,009
 
 
(177
)
 
(2,781
)
Income Tax Expense
$
154,928
 
 
$
132,935
 
 
$
165,527
 
 
 
 
 
 
 
Effective Income Tax Rate
41.8

%

 
40.8

%

 
39.1

%

I&M
Years Ended December 31,
 
2014
 
2013
 
2012
 
(in thousands)
Net Income
$
155,647
 
 
$
177,504
 
 
$
118,457
 
Income Tax Expense
79,621
 
 
75,111
 
 
39,344
 
Pretax Income
$
235,268
 
 
$
252,615
 
 
$
157,801
 
 
 
 
 
 
 
Income Taxes on Pretax Income at Statutory Rate (35%)
$
82,344
 
 
$
88,415
 
 
$
55,230
 
Increase (Decrease) in Income Taxes Resulting from the Following Items:
 
 
 
 
 
Depreciation
12,885
 
 
10,057
 
 
8,659
 
Investment Tax Credits, Net
(4,877
)
 
(4,931
)
 
(4,502
)
State and Local Income Taxes, Net
7,668
 
 
(882
)
 
(1,559
)
Removal Costs
(11,272
)
 
(9,432
)
 
(5,490
)
AFUDC
(9,994
)
 
(10,555
)
 
(7,218
)
Other
2,867
 
 
2,439
 
 
(5,776
)
Income Tax Expense
$
79,621
 
 
$
75,111
 
 
$
39,344
 
 
 
 
 
 
 
Effective Income Tax Rate
33.8

%

 
29.7

%

 
24.9

%


OPCo
Years Ended December 31,
 
2014
 
2013
 
2012
 
(in thousands)
Net Income
$
216,422
 
 
$
409,980
 
 
$
343,534
 
Income Tax Expense
132,207
 
 
225,670
 
 
144,283
 
Pretax Income
$
348,629
 
 
$
635,650
 
 
$
487,817
 
 
 
 
 
 
 
Income Taxes on Pretax Income at Statutory Rate (35%)
$
122,020
 
 
$
222,478
 
 
$
170,736
 
Increase (Decrease) in Income Taxes Resulting from the Following Items:
 
 
 
 
 
Depreciation
6,665
 
 
6,759
 
 
5,239
 
Investment Tax Credits, Net
(241
)
 
(1,418
)
 
(1,849
)
State and Local Income Taxes, Net
8,866
 
 
3,327
 
 
(18,291
)
Parent Company Loss Benefit
(996
)
 
(2,154
)
 
(11,915
)
Other
(4,107
)
 
(3,322
)
 
363
 
Income Tax Expense
$
132,207
 
 
$
225,670
 
 
$
144,283
 
 
 
 
 
 
 
Effective Income Tax Rate
37.9

%

 
35.5

%

 
29.6

%


PSO
Years Ended December 31,
 
2014
 
2013
 
2012
 
(in thousands)
Net Income
$
86,929
 
 
$
97,796
 
 
$
114,141
 
Income Tax Expense
50,582
 
 
65,885
 
 
66,694
 
Pretax Income
$
137,511
 
 
$
163,681
 
 
$
180,835
 
 
 
 
 
 
 
Income Taxes on Pretax Income at Statutory Rate (35%)
$
48,129
 
 
$
57,288
 
 
$
63,292
 
Increase (Decrease) in Income Taxes Resulting from the Following Items:
 
 
 
 
 
Depreciation
176
 
 
164
 
 
(10
)
Investment Tax Credits, Net
(770
)
 
(776
)
 
(781
)
State and Local Income Taxes, Net
4,777
 
 
5,423
 
 
6,953
 
Tax Adjustments
(1,241
)
 
5,268
 
 
201
 
Other
(489
)
 
(1,482
)
 
(2,961
)
Income Tax Expense
$
50,582
 
 
$
65,885
 
 
$
66,694
 
 
 
 
 
 
 
Effective Income Tax Rate
36.8

%

 
40.3

%

 
36.9

%


SWEPCo
Years Ended December 31,
 
2014
 
2013
 
2012
 
(in thousands)
Net Income
$
144,559
 
 
$
153,819
 
 
$
202,513
 
Income Tax Expense
66,420
 
 
69,461
 
 
45,858
 
Pretax Income
$
210,979
 
 
$
223,280
 
 
$
248,371
 
 
 
 
 
 
 
Income Taxes on Pretax Income at Statutory Rate (35%)
$
73,843
 
 
$
78,148
 
 
$
86,930
 
Increase (Decrease) in Income Taxes Resulting from the Following Items:
 
 
 
 
 
Depreciation
2,944
 
 
3,086
 
 
2,105
 
Depletion
(4,143
)
 
(3,472
)
 
(3,276
)
Investment Tax Credits, Net
(1,377
)
 
(1,561
)
 
(550
)
State and Local Income Taxes, Net
3,083
 
 
(1,453
)
 
(18,010
)
AFUDC
(4,182
)
 
(2,381
)
 
(19,879
)
Other
(3,748
)
 
(2,906
)
 
(1,462
)
Income Tax Expense
$
66,420
 
 
$
69,461
 
 
$
45,858
 
 
 
 
 
 
 
Effective Income Tax Rate
31.5

%

 
31.1

%

 
18.5

%



The following tables show elements of the net deferred tax liability and significant temporary differences for each Registrant Subsidiary:
APCo
December 31,
 
2014
 
2013
 
(in thousands)
Deferred Tax Assets
$
446,346

 
$
548,966

Deferred Tax Liabilities
(2,711,233
)
 
(2,788,306
)
Net Deferred Tax Liabilities
$
(2,264,887
)
 
$
(2,239,340
)
 
 
 
 
Property Related Temporary Differences
$
(1,801,885
)
 
$
(1,725,853
)
Amounts Due from Customers for Future Federal Income Taxes
(70,417
)
 
(94,775
)
Deferred State Income Taxes
(239,724
)
 
(246,247
)
Regulatory Assets
(113,671
)
 
(104,824
)
Securitized Assets
(122,559
)
 
(130,834
)
Deferred Income Taxes on Other Comprehensive Loss
(2,710
)
 
(1,589
)
Net Operating Loss Carryforward
9,796

 
45,177

Tax Credit Carryforward
46,162

 
21,940

Valuation Allowance

 
(41,277
)
All Other, Net
30,121

 
38,942

Net Deferred Tax Liabilities
$
(2,264,887
)
 
$
(2,239,340
)

I&M
December 31,
 
2014
 
2013
 
(in thousands)
Deferred Tax Assets
$
911,811

 
$
843,630

Deferred Tax Liabilities
(2,190,002
)
 
(2,043,810
)
Net Deferred Tax Liabilities
$
(1,278,191
)
 
$
(1,200,180
)
 
 
 
 
Property Related Temporary Differences
$
(418,724
)
 
$
(390,829
)
Amounts Due from Customers for Future Federal Income Taxes
(40,580
)
 
(39,137
)
Deferred State Income Taxes
(138,907
)
 
(137,162
)
Deferred Income Taxes on Other Comprehensive Loss
7,732

 
8,351

Accrued Nuclear Decommissioning
(610,955
)
 
(553,794
)
Net Operating Loss Carryforward

 
15,690

Regulatory Assets
(74,690
)
 
(59,008
)
All Other, Net
(2,067
)
 
(44,291
)
Net Deferred Tax Liabilities
$
(1,278,191
)
 
$
(1,200,180
)

OPCo
December 31,
 
2014
 
2013
 
(in thousands)
Deferred Tax Assets
$
171,816

 
$
183,085

Deferred Tax Liabilities
(1,528,130
)
 
(1,477,691
)
Net Deferred Tax Liabilities
$
(1,356,314
)
 
$
(1,294,606
)
 
 
 
 
Property Related Temporary Differences
$
(926,520
)
 
$
(841,607
)
Amounts Due from Customers for Future Federal Income Taxes
(47,598
)
 
(51,946
)
Deferred State Income Taxes
(34,232
)
 
(28,569
)
Regulatory Assets
(242,391
)
 
(215,535
)
Deferred Income Taxes on Other Comprehensive Loss
(3,016
)
 
(3,812
)
Deferred Fuel and Purchased Power
(145,515
)
 
(176,192
)
All Other, Net
42,958

 
23,055

Net Deferred Tax Liabilities
$
(1,356,314
)
 
$
(1,294,606
)

PSO
December 31,
 
2014
 
2013
 
(in thousands)
Deferred Tax Assets
$
110,758

 
$
107,567

Deferred Tax Liabilities
(1,016,721
)
 
(936,791
)
Net Deferred Tax Liabilities
$
(905,963
)
 
$
(829,224
)
 
 
 
 
Property Related Temporary Differences
$
(805,193
)
 
$
(736,160
)
Amounts Due from Customers for Future Federal Income Taxes
(678
)
 
(31
)
Deferred State Income Taxes
(109,285
)
 
(99,126
)
Regulatory Assets
(39,620
)
 
(39,414
)
Deferred Income Taxes on Other Comprehensive Loss
(2,661
)
 
(3,100
)
Deferred Federal Income Taxes on Deferred State Income Taxes
43,918

 
40,362

Net Operating Loss Carryforward
6,365

 
4,314

Tax Credit Carryforward
681

 
565

All Other, Net
510

 
3,366

Net Deferred Tax Liabilities
$
(905,963
)
 
$
(829,224
)

SWEPCo
December 31,
 
2014
 
2013
 
(in thousands)
Deferred Tax Assets
$
186,176

 
$
359,529

Deferred Tax Liabilities
(1,528,246
)
 
(1,453,710
)
Net Deferred Tax Liabilities
$
(1,342,070
)
 
$
(1,094,181
)
 
 
 
 
Property Related Temporary Differences
$
(1,235,136
)
 
$
(1,172,431
)
Amounts Due from Customers for Future Federal Income Taxes
(44,119
)
 
(43,116
)
Deferred State Income Taxes
(124,147
)
 
(118,179
)
Regulatory Assets
(19,388
)
 
(5,290
)
Deferred Income Taxes on Other Comprehensive Loss
4,021

 
4,548

Impairment Loss - Turk Plant
21,052

 
21,295

Net Operating Loss Carryforward
21,925

 
189,128

All Other, Net
33,722

 
29,864

Net Deferred Tax Liabilities
$
(1,342,070
)
 
$
(1,094,181
)


AEP System Tax Allocation Agreement

The Registrant Subsidiaries join in the filing of a consolidated federal income tax return with their affiliates in the AEP System.  The allocation of the AEP System’s current consolidated federal income tax to the AEP System companies allocates the benefit of current tax losses to the AEP System companies giving rise to such losses in determining their current tax expense.  The tax benefit of the Parent is allocated to its subsidiaries with taxable income.  With the exception of the loss of the Parent, the method of allocation reflects a separate return result for each company in the consolidated group.

Federal and State Income Tax Audit Status

The Registrant Subsidiaries are no longer subject to U.S. federal examination for years before 2011.  The IRS examination of years 2011, 2012 and 2013 started in April 2014. Although the outcome of tax audits is uncertain, in management’s opinion, adequate provisions for federal income taxes have been made for potential liabilities resulting from such matters.  In addition, the Registrant Subsidiaries accrue interest on these uncertain tax positions.  Management is not aware of any issues for open tax years that upon final resolution are expected to materially impact net income.

The Registrant Subsidiaries file income tax returns in various state and local jurisdictions.  These taxing authorities routinely examine their tax returns and the Registrant Subsidiaries are currently under examination in several state and local jurisdictions.  However, it is possible that previously filed tax returns have positions that may be challenged by these tax authorities.  Management believes that adequate provisions for income taxes have been made for potential liabilities resulting from such challenges and that the ultimate resolution of these audits will not materially impact net income.  The Registrant Subsidiaries are no longer subject to state or local income tax examinations by tax authorities for years before 2009.

Net Income Tax Operating Loss Carryforward

In 2011, APCo and I&M recognized federal net income tax operating losses of $313 million and $123 million, respectively, driven primarily by bonus depreciation, pension plan contributions and other book versus tax temporary differences.  In 2012, SWEPCo recognized a federal net income tax operating loss of $858 million driven primarily by bonus depreciation.  APCo, OPCo, PSO and SWEPCo also have state net income tax operating loss carryforwards as indicated in the table below:
Company
 
State
 
State Net Income
Tax Operating
Loss
Carryforward
 
Year of
Expiration
 
 
 
 
(in thousands)
 
 
APCo
 
Tennessee
 
$
2,695

 
2026
APCo
 
West Virginia
 
235,341

 
2032
OPCo
 
West Virginia
 
50,228

 
2032
PSO
 
Oklahoma
 
163,212

 
2034
SWEPCo
 
Louisiana
 
419,384

 
2029
SWEPCo
 
Oklahoma
 
2,994

 
2034


As a result, APCo, OPCo, PSO and SWEPCo recognized deferred state and local income tax benefits in 2011, and/or 2012, and/or 2013 and/or 2014.  At the end of 2013, APCo, I&M and SWEPCo had $12 million, $13 million and $167 million, respectively, of unrealized federal net operating loss carryforward.  Federal taxable income was sufficient enough in 2014 that these remaining federal net income tax operating loss tax benefits were realized in full.  Management also anticipates future taxable income will be sufficient to realize the remaining state net income tax operating loss tax benefits before the state carryforward expires for each state.

Tax Credit Carryforward

Federal and state net income tax operating losses sustained in 2011 and 2009 along with lower federal and state taxable income in 2010 resulted in unused federal and state income tax credits.  As of December 31, 2014, the Registrant Subsidiaries have federal tax credit carryforwards and PSO has state tax credit carryforwards as indicated in the table below.  If these credits are not utilized, federal general business tax credits will expire in the years 2029 through 2033.
Company
 
Total Federal
Tax Credit
Carryforward
 
Federal Tax
Credit
Carryforward
Subject to
Expiration
 
Total State
Tax Credit
Carryforward
 
State Tax
Credit
Carryforward
Subject to
Expiration
 
 
(in thousands)
APCo
 
$
45,654

 
$
4,046

 
$

 
$

I&M
 
3,418

 
2,877

 

 

OPCo
 
25,679

 
1,962

 

 

PSO
 
681

 
660

 
22,141

 
22,141

SWEPCo
 
3,254

 
899

 

 



The Registrant Subsidiaries anticipate future federal taxable income will be sufficient to realize the tax benefits of the federal tax credits before they expire unused.  In November 2014, APCo received an order from the Virginia SCC for its 2014 Virginia Biennial Base Rate Case (see Note 4). As a result of the final determination pertaining to the ability to realize future tax benefits for certain state net income tax operating loss and credit carryforwards, management determined that APCo is subject to the Virginia Minimum Tax on electric suppliers and the Virginia State Income Tax is no longer applicable. As a result, management derecognized the related state income tax benefits, which had been subject to valuation allowances.

Uncertain Tax Positions

The Registrant Subsidiaries recognize interest accruals related to uncertain tax positions in interest income or expense as applicable and penalties in Other Operation expense in accordance with the accounting guidance for “Income Taxes.”

The following tables show amounts reported for interest expense, interest income and reversal of prior period interest expense:
 
 
Years Ended December 31,
 
 
2014
 
2013
Company
 
Interest
Expense
 
Interest
Income
 
Reversal of
Prior Period
Interest
Expense
 
Interest
Expense
 
Interest
Income
 
Reversal of
Prior Period
Interest
Expense
 
 
(in thousands)
APCo
 
$

 
$

 
$
193

 
$

 
$
1,089

 
$

I&M
 

 

 
289

 

 
597

 

OPCo
 
129

 

 
245

 

 
1,892

 

PSO
 
88

 

 
137

 

 
135

 

SWEPCo
 
172

 

 
154

 
215

 

 

 
 
Year Ended December 31, 2012
Company
 
Interest
Expense
 
Interest
Income
 
Reversal of
Prior Period
Interest
Expense
 
 
(in thousands)
APCo
 
$
62

 
$

 
$
183

I&M
 
1,355

 

 

OPCo
 
266

 

 
504

PSO
 
259

 

 
294

SWEPCo
 
286

 

 
271



The following table shows balances for amounts accrued for the receipt of interest:
 
 
December 31,
Company
 
2014
 
2013
 
 
(in thousands)
APCo
 
$

 
$

I&M
 

 

OPCo
 

 

PSO
 

 
209

SWEPCo
 

 
172



The following table shows balances for amounts accrued for the payment of interest and penalties:
 
 
December 31,
Company
 
2014
 
2013
 
 
(in thousands)
APCo
 
$

 
$
158

I&M
 
526

 
957

OPCo
 
382

 
407

PSO
 
310

 
562

SWEPCo
 
1,010

 
1,167



The reconciliations of the beginning and ending amounts of unrecognized tax benefits are as follows:
 
APCo
 
I&M
 
OPCo
 
PSO
 
SWEPCo
 
(in thousands)
Balance as of January 1, 2014
$
1,164

 
$
3,164

 
$
2,086

 
$
2,184

 
$
7,602

Increase  Tax Positions Taken During a Prior Period

 
1,431

 
6,335

 
64

 
1,602

Decrease  Tax Positions Taken During a Prior Period

 

 

 
(18
)
 
(832
)
Increase  Tax Positions Taken During the Current Year

 

 

 

 

Decrease  Tax Positions Taken During the Current Year

 

 

 

 

Increase  Settlements with Taxing Authorities
1

 

 
70

 
37

 

Decrease  Settlements with Taxing Authorities

 
(660
)
 

 

 
(30
)
Decrease  Lapse of the Applicable Statute of Limitations
(1,165
)
 
(1,640
)
 
(1,566
)
 
(948
)
 
(845
)
Balance as of December 31, 2014
$

 
$
2,295

 
$
6,925

 
$
1,319

 
$
7,497

 
APCo
 
I&M
 
OPCo
 
PSO
 
SWEPCo
 
(in thousands)
Balance as of January 1, 2013
$
5,253

 
$
15,085

 
$
11,052

 
$
2,273

 
$
9,553

Increase  Tax Positions Taken During a Prior Period

 

 

 

 

Decrease  Tax Positions Taken During a Prior Period
(4,089
)
 
(11,921
)
 
(8,966
)
 
(103
)
 
(3,158
)
Increase  Tax Positions Taken During the Current Year

 

 

 
14

 
1,301

Decrease  Tax Positions Taken During the Current Year

 

 

 

 

Decrease  Settlements with Taxing Authorities

 

 

 

 
(94
)
Decrease  Lapse of the Applicable Statute of Limitations

 

 

 

 

Balance as of December 31, 2013
$
1,164

 
$
3,164

 
$
2,086

 
$
2,184

 
$
7,602

 
APCo
 
I&M
 
OPCo
 
PSO
 
SWEPCo
 
(in thousands)
Balance as of January 1, 2012
$
7,311

 
$
14,071

 
$
43,565

 
$
3,585

 
$
9,031

Increase  Tax Positions Taken During a Prior Period

 
2,266

 
1,360

 
421

 
2,806

Decrease  Tax Positions Taken During a Prior Period
(384
)
 
(1,252
)
 
(13,582
)
 
(92
)
 
(775
)
Increase  Tax Positions Taken During the Current Year

 

 

 

 

Decrease  Tax Positions Taken During the Current Year

 

 

 

 

Decrease  Settlements with Taxing Authorities
(1,674
)
 

 
(20,291
)
 

 

Decrease  Lapse of the Applicable Statute of Limitations

 

 

 
(1,641
)
 
(1,509
)
Balance as of December 31, 2012
$
5,253

 
$
15,085

 
$
11,052

 
$
2,273

 
$
9,553



Management believes that there will be no significant net increase or decrease in unrecognized benefits within 12 months of the reporting date.  The total amount of unrecognized tax benefits that, if recognized, would affect the effective tax rate for each Registrant Subsidiary was as follows:
Company
 
2014
 
2013
 
2012
 
 
(in thousands)
APCo
 
$

 
$

 
$

I&M
 
1,591

 
1,220

 
1,220

OPCo
 
4,462

 
674

 
674

PSO
 
858

 
827

 
818

SWEPCo
 
4,873

 
4,357

 
3,512



Federal Tax Legislation – Affecting APCo, I&M, OPCo, PSO and SWEPCo

The American Taxpayer Relief Act of 2012 (the 2012 Act) was enacted in January 2013.  Included in the 2012 Act was a one-year extension of 50% bonus depreciation.  The 2012 Act also retroactively extended the life of research and development, employment and several energy tax credits, which expired at the end of 2011.  The enacted provisions did not materially impact the Registrant Subsidiaries’ net income or financial condition but did have a favorable impact on cash flows in 2013.

The Tax Increase Prevention Act of 2014 (the 2014 Act) was enacted in December 2014. Included in the 2014 Act was a one-year extension of the 50% bonus depreciation. The 2014 Act also retroactively extended the life of research and development, employment and several energy tax credits, which expired at the end of 2013. The enacted provisions did not materially impact the Registrant Subsidiaries' net income or financial condition but will have a favorable impact on future cash flows.

Federal Tax Regulations

In 2013, the U.S. Treasury Department issued final and re-proposed regulations regarding the deduction and capitalization of expenditures related to tangible property, effective for the tax years beginning in 2014.  In addition, the IRS issued Revenue Procedures under the Industry Issue Resolutions program that provides specific guidance for the implementation of the regulations for the electric utility industry.  These final regulations did not materially impact the Registrant Subsidiaries' net income, cash flows or financial condition.

State Tax Legislation – Affecting APCo, I&M and OPCo

Legislation was passed by the state of Indiana in May 2011 enacting a phased reduction in corporate income tax rate from 8.5% to 6.5%.  The 8.5% Indiana corporate income tax rate will be reduced 0.5% each year beginning after June 30, 2012 with the final reduction occurring in years beginning after June 30, 2015.

In May 2011, Michigan repealed its Business Tax regime and replaced it with a traditional corporate net income tax rate of 6%, effective January 1, 2012.

During the third quarter of 2013, it was determined that the state of West Virginia had achieved certain minimum levels of shortfall reserve funds.  As a result, the West Virginia corporate income tax rate was reduced from 7% to 6.5% in 2014.  

The enacted provisions did not materially impact the Registrant Subsidiaries’ net income, cash flows or financial condition.
Ohio Power Co [Member]  
Income Taxes
INCOME TAXES

The details of the Registrant Subsidiaries’ income taxes as reported are as follows:
Year Ended December 31, 2014
 
APCo
 
I&M
 
OPCo
 
PSO
 
SWEPCo
 
 
(in thousands)
Income Tax Expense (Credit):
 
 
 
 
 
 
 
 
 
 
Current
 
$
10,926

 
$
14,273

 
$
58,057

 
$
(24,349
)
 
$
(171,629
)
Deferred
 
144,651

 
70,225

 
74,391

 
74,756

 
239,426

Deferred Investment Tax Credits
 
(649
)
 
(4,877
)
 
(241
)
 
175

 
(1,377
)
Income Tax Expense
 
$
154,928

 
$
79,621

 
$
132,207

 
$
50,582

 
$
66,420

Year Ended December 31, 2013
 
APCo
 
I&M
 
OPCo
 
PSO
 
SWEPCo
 
 
(in thousands)
Income Tax Expense (Credit):
 
 
 
 
 
 
 
 
 
 
Current
 
$
58,441

 
$
(49,067
)
 
$
92,625

 
$
7,689

 
$
(10,866
)
Deferred
 
75,714

 
129,109

 
134,463

 
53,788

 
81,888

Deferred Investment Tax Credits
 
(1,220
)
 
(4,931
)
 
(1,418
)
 
4,408

 
(1,561
)
Income Tax Expense
 
$
132,935

 
$
75,111

 
$
225,670

 
$
65,885

 
$
69,461

Year Ended December 31, 2012
 
APCo
 
I&M
 
OPCo
 
PSO
 
SWEPCo
 
 
(in thousands)
Income Tax Expense (Credit):
 
 
 
 
 
 
 
 
 
 
Current
 
$
28,307

 
$
(9,221
)
 
$
100,447

 
$
18,634

 
$
(214,353
)
Deferred
 
138,460

 
53,067

 
45,685

 
48,916

 
260,761

Deferred Investment Tax Credits
 
(1,240
)
 
(4,502
)
 
(1,849
)
 
(856
)
 
(550
)
Income Tax Expense
 
$
165,527

 
$
39,344

 
$
144,283

 
$
66,694

 
$
45,858



Shown below for each Registrant Subsidiary is a reconciliation of the difference between the amounts of federal income taxes computed by multiplying book income before income taxes by the federal statutory tax rate and the amount of income taxes reported:
APCo
Years Ended December 31,
 
2014
 
2013
 
2012
 
(in thousands)
Net Income
$
215,415
 
 
$
193,211
 
 
$
257,503
 
Income Tax Expense
154,928
 
 
132,935
 
 
165,527
 
Pretax Income
$
370,343
 
 
$
326,146
 
 
$
423,030
 
 
 
 
 
 
 
Income Taxes on Pretax Income at Statutory Rate (35%)
$
129,620
 
 
$
114,151
 
 
$
148,061
 
Increase (Decrease) in Income Taxes Resulting from the Following Items:
 
 
 
 
 
Depreciation
23,527
 
 
20,286
 
 
20,424
 
Investment Tax Credits, Net
(649
)
 
(1,220
)
 
(1,240
)
State and Local Income Taxes, Net
6,531
 
 
2,707
 
 
3,175
 
Removal Costs
(6,844
)
 
(6,454
)
 
(6,641
)
AFUDC
(3,768
)
 
(1,420
)
 
(1,145
)
Valuation Allowance
(2,498
)
 
5,062
 
 
5,674
 
Other
9,009
 
 
(177
)
 
(2,781
)
Income Tax Expense
$
154,928
 
 
$
132,935
 
 
$
165,527
 
 
 
 
 
 
 
Effective Income Tax Rate
41.8

%

 
40.8

%

 
39.1

%

I&M
Years Ended December 31,
 
2014
 
2013
 
2012
 
(in thousands)
Net Income
$
155,647
 
 
$
177,504
 
 
$
118,457
 
Income Tax Expense
79,621
 
 
75,111
 
 
39,344
 
Pretax Income
$
235,268
 
 
$
252,615
 
 
$
157,801
 
 
 
 
 
 
 
Income Taxes on Pretax Income at Statutory Rate (35%)
$
82,344
 
 
$
88,415
 
 
$
55,230
 
Increase (Decrease) in Income Taxes Resulting from the Following Items:
 
 
 
 
 
Depreciation
12,885
 
 
10,057
 
 
8,659
 
Investment Tax Credits, Net
(4,877
)
 
(4,931
)
 
(4,502
)
State and Local Income Taxes, Net
7,668
 
 
(882
)
 
(1,559
)
Removal Costs
(11,272
)
 
(9,432
)
 
(5,490
)
AFUDC
(9,994
)
 
(10,555
)
 
(7,218
)
Other
2,867
 
 
2,439
 
 
(5,776
)
Income Tax Expense
$
79,621
 
 
$
75,111
 
 
$
39,344
 
 
 
 
 
 
 
Effective Income Tax Rate
33.8

%

 
29.7

%

 
24.9

%


OPCo
Years Ended December 31,
 
2014
 
2013
 
2012
 
(in thousands)
Net Income
$
216,422
 
 
$
409,980
 
 
$
343,534
 
Income Tax Expense
132,207
 
 
225,670
 
 
144,283
 
Pretax Income
$
348,629
 
 
$
635,650
 
 
$
487,817
 
 
 
 
 
 
 
Income Taxes on Pretax Income at Statutory Rate (35%)
$
122,020
 
 
$
222,478
 
 
$
170,736
 
Increase (Decrease) in Income Taxes Resulting from the Following Items:
 
 
 
 
 
Depreciation
6,665
 
 
6,759
 
 
5,239
 
Investment Tax Credits, Net
(241
)
 
(1,418
)
 
(1,849
)
State and Local Income Taxes, Net
8,866
 
 
3,327
 
 
(18,291
)
Parent Company Loss Benefit
(996
)
 
(2,154
)
 
(11,915
)
Other
(4,107
)
 
(3,322
)
 
363
 
Income Tax Expense
$
132,207
 
 
$
225,670
 
 
$
144,283
 
 
 
 
 
 
 
Effective Income Tax Rate
37.9

%

 
35.5

%

 
29.6

%


PSO
Years Ended December 31,
 
2014
 
2013
 
2012
 
(in thousands)
Net Income
$
86,929
 
 
$
97,796
 
 
$
114,141
 
Income Tax Expense
50,582
 
 
65,885
 
 
66,694
 
Pretax Income
$
137,511
 
 
$
163,681
 
 
$
180,835
 
 
 
 
 
 
 
Income Taxes on Pretax Income at Statutory Rate (35%)
$
48,129
 
 
$
57,288
 
 
$
63,292
 
Increase (Decrease) in Income Taxes Resulting from the Following Items:
 
 
 
 
 
Depreciation
176
 
 
164
 
 
(10
)
Investment Tax Credits, Net
(770
)
 
(776
)
 
(781
)
State and Local Income Taxes, Net
4,777
 
 
5,423
 
 
6,953
 
Tax Adjustments
(1,241
)
 
5,268
 
 
201
 
Other
(489
)
 
(1,482
)
 
(2,961
)
Income Tax Expense
$
50,582
 
 
$
65,885
 
 
$
66,694
 
 
 
 
 
 
 
Effective Income Tax Rate
36.8

%

 
40.3

%

 
36.9

%


SWEPCo
Years Ended December 31,
 
2014
 
2013
 
2012
 
(in thousands)
Net Income
$
144,559
 
 
$
153,819
 
 
$
202,513
 
Income Tax Expense
66,420
 
 
69,461
 
 
45,858
 
Pretax Income
$
210,979
 
 
$
223,280
 
 
$
248,371
 
 
 
 
 
 
 
Income Taxes on Pretax Income at Statutory Rate (35%)
$
73,843
 
 
$
78,148
 
 
$
86,930
 
Increase (Decrease) in Income Taxes Resulting from the Following Items:
 
 
 
 
 
Depreciation
2,944
 
 
3,086
 
 
2,105
 
Depletion
(4,143
)
 
(3,472
)
 
(3,276
)
Investment Tax Credits, Net
(1,377
)
 
(1,561
)
 
(550
)
State and Local Income Taxes, Net
3,083
 
 
(1,453
)
 
(18,010
)
AFUDC
(4,182
)
 
(2,381
)
 
(19,879
)
Other
(3,748
)
 
(2,906
)
 
(1,462
)
Income Tax Expense
$
66,420
 
 
$
69,461
 
 
$
45,858
 
 
 
 
 
 
 
Effective Income Tax Rate
31.5

%

 
31.1

%

 
18.5

%



The following tables show elements of the net deferred tax liability and significant temporary differences for each Registrant Subsidiary:
APCo
December 31,
 
2014
 
2013
 
(in thousands)
Deferred Tax Assets
$
446,346

 
$
548,966

Deferred Tax Liabilities
(2,711,233
)
 
(2,788,306
)
Net Deferred Tax Liabilities
$
(2,264,887
)
 
$
(2,239,340
)
 
 
 
 
Property Related Temporary Differences
$
(1,801,885
)
 
$
(1,725,853
)
Amounts Due from Customers for Future Federal Income Taxes
(70,417
)
 
(94,775
)
Deferred State Income Taxes
(239,724
)
 
(246,247
)
Regulatory Assets
(113,671
)
 
(104,824
)
Securitized Assets
(122,559
)
 
(130,834
)
Deferred Income Taxes on Other Comprehensive Loss
(2,710
)
 
(1,589
)
Net Operating Loss Carryforward
9,796

 
45,177

Tax Credit Carryforward
46,162

 
21,940

Valuation Allowance

 
(41,277
)
All Other, Net
30,121

 
38,942

Net Deferred Tax Liabilities
$
(2,264,887
)
 
$
(2,239,340
)

I&M
December 31,
 
2014
 
2013
 
(in thousands)
Deferred Tax Assets
$
911,811

 
$
843,630

Deferred Tax Liabilities
(2,190,002
)
 
(2,043,810
)
Net Deferred Tax Liabilities
$
(1,278,191
)
 
$
(1,200,180
)
 
 
 
 
Property Related Temporary Differences
$
(418,724
)
 
$
(390,829
)
Amounts Due from Customers for Future Federal Income Taxes
(40,580
)
 
(39,137
)
Deferred State Income Taxes
(138,907
)
 
(137,162
)
Deferred Income Taxes on Other Comprehensive Loss
7,732

 
8,351

Accrued Nuclear Decommissioning
(610,955
)
 
(553,794
)
Net Operating Loss Carryforward

 
15,690

Regulatory Assets
(74,690
)
 
(59,008
)
All Other, Net
(2,067
)
 
(44,291
)
Net Deferred Tax Liabilities
$
(1,278,191
)
 
$
(1,200,180
)

OPCo
December 31,
 
2014
 
2013
 
(in thousands)
Deferred Tax Assets
$
171,816

 
$
183,085

Deferred Tax Liabilities
(1,528,130
)
 
(1,477,691
)
Net Deferred Tax Liabilities
$
(1,356,314
)
 
$
(1,294,606
)
 
 
 
 
Property Related Temporary Differences
$
(926,520
)
 
$
(841,607
)
Amounts Due from Customers for Future Federal Income Taxes
(47,598
)
 
(51,946
)
Deferred State Income Taxes
(34,232
)
 
(28,569
)
Regulatory Assets
(242,391
)
 
(215,535
)
Deferred Income Taxes on Other Comprehensive Loss
(3,016
)
 
(3,812
)
Deferred Fuel and Purchased Power
(145,515
)
 
(176,192
)
All Other, Net
42,958

 
23,055

Net Deferred Tax Liabilities
$
(1,356,314
)
 
$
(1,294,606
)

PSO
December 31,
 
2014
 
2013
 
(in thousands)
Deferred Tax Assets
$
110,758

 
$
107,567

Deferred Tax Liabilities
(1,016,721
)
 
(936,791
)
Net Deferred Tax Liabilities
$
(905,963
)
 
$
(829,224
)
 
 
 
 
Property Related Temporary Differences
$
(805,193
)
 
$
(736,160
)
Amounts Due from Customers for Future Federal Income Taxes
(678
)
 
(31
)
Deferred State Income Taxes
(109,285
)
 
(99,126
)
Regulatory Assets
(39,620
)
 
(39,414
)
Deferred Income Taxes on Other Comprehensive Loss
(2,661
)
 
(3,100
)
Deferred Federal Income Taxes on Deferred State Income Taxes
43,918

 
40,362

Net Operating Loss Carryforward
6,365

 
4,314

Tax Credit Carryforward
681

 
565

All Other, Net
510

 
3,366

Net Deferred Tax Liabilities
$
(905,963
)
 
$
(829,224
)

SWEPCo
December 31,
 
2014
 
2013
 
(in thousands)
Deferred Tax Assets
$
186,176

 
$
359,529

Deferred Tax Liabilities
(1,528,246
)
 
(1,453,710
)
Net Deferred Tax Liabilities
$
(1,342,070
)
 
$
(1,094,181
)
 
 
 
 
Property Related Temporary Differences
$
(1,235,136
)
 
$
(1,172,431
)
Amounts Due from Customers for Future Federal Income Taxes
(44,119
)
 
(43,116
)
Deferred State Income Taxes
(124,147
)
 
(118,179
)
Regulatory Assets
(19,388
)
 
(5,290
)
Deferred Income Taxes on Other Comprehensive Loss
4,021

 
4,548

Impairment Loss - Turk Plant
21,052

 
21,295

Net Operating Loss Carryforward
21,925

 
189,128

All Other, Net
33,722

 
29,864

Net Deferred Tax Liabilities
$
(1,342,070
)
 
$
(1,094,181
)


AEP System Tax Allocation Agreement

The Registrant Subsidiaries join in the filing of a consolidated federal income tax return with their affiliates in the AEP System.  The allocation of the AEP System’s current consolidated federal income tax to the AEP System companies allocates the benefit of current tax losses to the AEP System companies giving rise to such losses in determining their current tax expense.  The tax benefit of the Parent is allocated to its subsidiaries with taxable income.  With the exception of the loss of the Parent, the method of allocation reflects a separate return result for each company in the consolidated group.

Federal and State Income Tax Audit Status

The Registrant Subsidiaries are no longer subject to U.S. federal examination for years before 2011.  The IRS examination of years 2011, 2012 and 2013 started in April 2014. Although the outcome of tax audits is uncertain, in management’s opinion, adequate provisions for federal income taxes have been made for potential liabilities resulting from such matters.  In addition, the Registrant Subsidiaries accrue interest on these uncertain tax positions.  Management is not aware of any issues for open tax years that upon final resolution are expected to materially impact net income.

The Registrant Subsidiaries file income tax returns in various state and local jurisdictions.  These taxing authorities routinely examine their tax returns and the Registrant Subsidiaries are currently under examination in several state and local jurisdictions.  However, it is possible that previously filed tax returns have positions that may be challenged by these tax authorities.  Management believes that adequate provisions for income taxes have been made for potential liabilities resulting from such challenges and that the ultimate resolution of these audits will not materially impact net income.  The Registrant Subsidiaries are no longer subject to state or local income tax examinations by tax authorities for years before 2009.

Net Income Tax Operating Loss Carryforward

In 2011, APCo and I&M recognized federal net income tax operating losses of $313 million and $123 million, respectively, driven primarily by bonus depreciation, pension plan contributions and other book versus tax temporary differences.  In 2012, SWEPCo recognized a federal net income tax operating loss of $858 million driven primarily by bonus depreciation.  APCo, OPCo, PSO and SWEPCo also have state net income tax operating loss carryforwards as indicated in the table below:
Company
 
State
 
State Net Income
Tax Operating
Loss
Carryforward
 
Year of
Expiration
 
 
 
 
(in thousands)
 
 
APCo
 
Tennessee
 
$
2,695

 
2026
APCo
 
West Virginia
 
235,341

 
2032
OPCo
 
West Virginia
 
50,228

 
2032
PSO
 
Oklahoma
 
163,212

 
2034
SWEPCo
 
Louisiana
 
419,384

 
2029
SWEPCo
 
Oklahoma
 
2,994

 
2034


As a result, APCo, OPCo, PSO and SWEPCo recognized deferred state and local income tax benefits in 2011, and/or 2012, and/or 2013 and/or 2014.  At the end of 2013, APCo, I&M and SWEPCo had $12 million, $13 million and $167 million, respectively, of unrealized federal net operating loss carryforward.  Federal taxable income was sufficient enough in 2014 that these remaining federal net income tax operating loss tax benefits were realized in full.  Management also anticipates future taxable income will be sufficient to realize the remaining state net income tax operating loss tax benefits before the state carryforward expires for each state.

Tax Credit Carryforward

Federal and state net income tax operating losses sustained in 2011 and 2009 along with lower federal and state taxable income in 2010 resulted in unused federal and state income tax credits.  As of December 31, 2014, the Registrant Subsidiaries have federal tax credit carryforwards and PSO has state tax credit carryforwards as indicated in the table below.  If these credits are not utilized, federal general business tax credits will expire in the years 2029 through 2033.
Company
 
Total Federal
Tax Credit
Carryforward
 
Federal Tax
Credit
Carryforward
Subject to
Expiration
 
Total State
Tax Credit
Carryforward
 
State Tax
Credit
Carryforward
Subject to
Expiration
 
 
(in thousands)
APCo
 
$
45,654

 
$
4,046

 
$

 
$

I&M
 
3,418

 
2,877

 

 

OPCo
 
25,679

 
1,962

 

 

PSO
 
681

 
660

 
22,141

 
22,141

SWEPCo
 
3,254

 
899

 

 



The Registrant Subsidiaries anticipate future federal taxable income will be sufficient to realize the tax benefits of the federal tax credits before they expire unused.  In November 2014, APCo received an order from the Virginia SCC for its 2014 Virginia Biennial Base Rate Case (see Note 4). As a result of the final determination pertaining to the ability to realize future tax benefits for certain state net income tax operating loss and credit carryforwards, management determined that APCo is subject to the Virginia Minimum Tax on electric suppliers and the Virginia State Income Tax is no longer applicable. As a result, management derecognized the related state income tax benefits, which had been subject to valuation allowances.

Uncertain Tax Positions

The Registrant Subsidiaries recognize interest accruals related to uncertain tax positions in interest income or expense as applicable and penalties in Other Operation expense in accordance with the accounting guidance for “Income Taxes.”

The following tables show amounts reported for interest expense, interest income and reversal of prior period interest expense:
 
 
Years Ended December 31,
 
 
2014
 
2013
Company
 
Interest
Expense
 
Interest
Income
 
Reversal of
Prior Period
Interest
Expense
 
Interest
Expense
 
Interest
Income
 
Reversal of
Prior Period
Interest
Expense
 
 
(in thousands)
APCo
 
$

 
$

 
$
193

 
$

 
$
1,089

 
$

I&M
 

 

 
289

 

 
597

 

OPCo
 
129

 

 
245

 

 
1,892

 

PSO
 
88

 

 
137

 

 
135

 

SWEPCo
 
172

 

 
154

 
215

 

 

 
 
Year Ended December 31, 2012
Company
 
Interest
Expense
 
Interest
Income
 
Reversal of
Prior Period
Interest
Expense
 
 
(in thousands)
APCo
 
$
62

 
$

 
$
183

I&M
 
1,355

 

 

OPCo
 
266

 

 
504

PSO
 
259

 

 
294

SWEPCo
 
286

 

 
271



The following table shows balances for amounts accrued for the receipt of interest:
 
 
December 31,
Company
 
2014
 
2013
 
 
(in thousands)
APCo
 
$

 
$

I&M
 

 

OPCo
 

 

PSO
 

 
209

SWEPCo
 

 
172



The following table shows balances for amounts accrued for the payment of interest and penalties:
 
 
December 31,
Company
 
2014
 
2013
 
 
(in thousands)
APCo
 
$

 
$
158

I&M
 
526

 
957

OPCo
 
382

 
407

PSO
 
310

 
562

SWEPCo
 
1,010

 
1,167



The reconciliations of the beginning and ending amounts of unrecognized tax benefits are as follows:
 
APCo
 
I&M
 
OPCo
 
PSO
 
SWEPCo
 
(in thousands)
Balance as of January 1, 2014
$
1,164

 
$
3,164

 
$
2,086

 
$
2,184

 
$
7,602

Increase  Tax Positions Taken During a Prior Period

 
1,431

 
6,335

 
64

 
1,602

Decrease  Tax Positions Taken During a Prior Period

 

 

 
(18
)
 
(832
)
Increase  Tax Positions Taken During the Current Year

 

 

 

 

Decrease  Tax Positions Taken During the Current Year

 

 

 

 

Increase  Settlements with Taxing Authorities
1

 

 
70

 
37

 

Decrease  Settlements with Taxing Authorities

 
(660
)
 

 

 
(30
)
Decrease  Lapse of the Applicable Statute of Limitations
(1,165
)
 
(1,640
)
 
(1,566
)
 
(948
)
 
(845
)
Balance as of December 31, 2014
$

 
$
2,295

 
$
6,925

 
$
1,319

 
$
7,497

 
APCo
 
I&M
 
OPCo
 
PSO
 
SWEPCo
 
(in thousands)
Balance as of January 1, 2013
$
5,253

 
$
15,085

 
$
11,052

 
$
2,273

 
$
9,553

Increase  Tax Positions Taken During a Prior Period

 

 

 

 

Decrease  Tax Positions Taken During a Prior Period
(4,089
)
 
(11,921
)
 
(8,966
)
 
(103
)
 
(3,158
)
Increase  Tax Positions Taken During the Current Year

 

 

 
14

 
1,301

Decrease  Tax Positions Taken During the Current Year

 

 

 

 

Decrease  Settlements with Taxing Authorities

 

 

 

 
(94
)
Decrease  Lapse of the Applicable Statute of Limitations

 

 

 

 

Balance as of December 31, 2013
$
1,164

 
$
3,164

 
$
2,086

 
$
2,184

 
$
7,602

 
APCo
 
I&M
 
OPCo
 
PSO
 
SWEPCo
 
(in thousands)
Balance as of January 1, 2012
$
7,311

 
$
14,071

 
$
43,565

 
$
3,585

 
$
9,031

Increase  Tax Positions Taken During a Prior Period

 
2,266

 
1,360

 
421

 
2,806

Decrease  Tax Positions Taken During a Prior Period
(384
)
 
(1,252
)
 
(13,582
)
 
(92
)
 
(775
)
Increase  Tax Positions Taken During the Current Year

 

 

 

 

Decrease  Tax Positions Taken During the Current Year

 

 

 

 

Decrease  Settlements with Taxing Authorities
(1,674
)
 

 
(20,291
)
 

 

Decrease  Lapse of the Applicable Statute of Limitations

 

 

 
(1,641
)
 
(1,509
)
Balance as of December 31, 2012
$
5,253

 
$
15,085

 
$
11,052

 
$
2,273

 
$
9,553



Management believes that there will be no significant net increase or decrease in unrecognized benefits within 12 months of the reporting date.  The total amount of unrecognized tax benefits that, if recognized, would affect the effective tax rate for each Registrant Subsidiary was as follows:
Company
 
2014
 
2013
 
2012
 
 
(in thousands)
APCo
 
$

 
$

 
$

I&M
 
1,591

 
1,220

 
1,220

OPCo
 
4,462

 
674

 
674

PSO
 
858

 
827

 
818

SWEPCo
 
4,873

 
4,357

 
3,512



Federal Tax Legislation – Affecting APCo, I&M, OPCo, PSO and SWEPCo

The American Taxpayer Relief Act of 2012 (the 2012 Act) was enacted in January 2013.  Included in the 2012 Act was a one-year extension of 50% bonus depreciation.  The 2012 Act also retroactively extended the life of research and development, employment and several energy tax credits, which expired at the end of 2011.  The enacted provisions did not materially impact the Registrant Subsidiaries’ net income or financial condition but did have a favorable impact on cash flows in 2013.

The Tax Increase Prevention Act of 2014 (the 2014 Act) was enacted in December 2014. Included in the 2014 Act was a one-year extension of the 50% bonus depreciation. The 2014 Act also retroactively extended the life of research and development, employment and several energy tax credits, which expired at the end of 2013. The enacted provisions did not materially impact the Registrant Subsidiaries' net income or financial condition but will have a favorable impact on future cash flows.

Federal Tax Regulations

In 2013, the U.S. Treasury Department issued final and re-proposed regulations regarding the deduction and capitalization of expenditures related to tangible property, effective for the tax years beginning in 2014.  In addition, the IRS issued Revenue Procedures under the Industry Issue Resolutions program that provides specific guidance for the implementation of the regulations for the electric utility industry.  These final regulations did not materially impact the Registrant Subsidiaries' net income, cash flows or financial condition.

State Tax Legislation – Affecting APCo, I&M and OPCo

Legislation was passed by the state of Indiana in May 2011 enacting a phased reduction in corporate income tax rate from 8.5% to 6.5%.  The 8.5% Indiana corporate income tax rate will be reduced 0.5% each year beginning after June 30, 2012 with the final reduction occurring in years beginning after June 30, 2015.

In May 2011, Michigan repealed its Business Tax regime and replaced it with a traditional corporate net income tax rate of 6%, effective January 1, 2012.

During the third quarter of 2013, it was determined that the state of West Virginia had achieved certain minimum levels of shortfall reserve funds.  As a result, the West Virginia corporate income tax rate was reduced from 7% to 6.5% in 2014.  

The enacted provisions did not materially impact the Registrant Subsidiaries’ net income, cash flows or financial condition.
Public Service Co Of Oklahoma [Member]  
Income Taxes
INCOME TAXES

The details of the Registrant Subsidiaries’ income taxes as reported are as follows:
Year Ended December 31, 2014
 
APCo
 
I&M
 
OPCo
 
PSO
 
SWEPCo
 
 
(in thousands)
Income Tax Expense (Credit):
 
 
 
 
 
 
 
 
 
 
Current
 
$
10,926

 
$
14,273

 
$
58,057

 
$
(24,349
)
 
$
(171,629
)
Deferred
 
144,651

 
70,225

 
74,391

 
74,756

 
239,426

Deferred Investment Tax Credits
 
(649
)
 
(4,877
)
 
(241
)
 
175

 
(1,377
)
Income Tax Expense
 
$
154,928

 
$
79,621

 
$
132,207

 
$
50,582

 
$
66,420

Year Ended December 31, 2013
 
APCo
 
I&M
 
OPCo
 
PSO
 
SWEPCo
 
 
(in thousands)
Income Tax Expense (Credit):
 
 
 
 
 
 
 
 
 
 
Current
 
$
58,441

 
$
(49,067
)
 
$
92,625

 
$
7,689

 
$
(10,866
)
Deferred
 
75,714

 
129,109

 
134,463

 
53,788

 
81,888

Deferred Investment Tax Credits
 
(1,220
)
 
(4,931
)
 
(1,418
)
 
4,408

 
(1,561
)
Income Tax Expense
 
$
132,935

 
$
75,111

 
$
225,670

 
$
65,885

 
$
69,461

Year Ended December 31, 2012
 
APCo
 
I&M
 
OPCo
 
PSO
 
SWEPCo
 
 
(in thousands)
Income Tax Expense (Credit):
 
 
 
 
 
 
 
 
 
 
Current
 
$
28,307

 
$
(9,221
)
 
$
100,447

 
$
18,634

 
$
(214,353
)
Deferred
 
138,460

 
53,067

 
45,685

 
48,916

 
260,761

Deferred Investment Tax Credits
 
(1,240
)
 
(4,502
)
 
(1,849
)
 
(856
)
 
(550
)
Income Tax Expense
 
$
165,527

 
$
39,344

 
$
144,283

 
$
66,694

 
$
45,858



Shown below for each Registrant Subsidiary is a reconciliation of the difference between the amounts of federal income taxes computed by multiplying book income before income taxes by the federal statutory tax rate and the amount of income taxes reported:
APCo
Years Ended December 31,
 
2014
 
2013
 
2012
 
(in thousands)
Net Income
$
215,415
 
 
$
193,211
 
 
$
257,503
 
Income Tax Expense
154,928
 
 
132,935
 
 
165,527
 
Pretax Income
$
370,343
 
 
$
326,146
 
 
$
423,030
 
 
 
 
 
 
 
Income Taxes on Pretax Income at Statutory Rate (35%)
$
129,620
 
 
$
114,151
 
 
$
148,061
 
Increase (Decrease) in Income Taxes Resulting from the Following Items:
 
 
 
 
 
Depreciation
23,527
 
 
20,286
 
 
20,424
 
Investment Tax Credits, Net
(649
)
 
(1,220
)
 
(1,240
)
State and Local Income Taxes, Net
6,531
 
 
2,707
 
 
3,175
 
Removal Costs
(6,844
)
 
(6,454
)
 
(6,641
)
AFUDC
(3,768
)
 
(1,420
)
 
(1,145
)
Valuation Allowance
(2,498
)
 
5,062
 
 
5,674
 
Other
9,009
 
 
(177
)
 
(2,781
)
Income Tax Expense
$
154,928
 
 
$
132,935
 
 
$
165,527
 
 
 
 
 
 
 
Effective Income Tax Rate
41.8

%

 
40.8

%

 
39.1

%

I&M
Years Ended December 31,
 
2014
 
2013
 
2012
 
(in thousands)
Net Income
$
155,647
 
 
$
177,504
 
 
$
118,457
 
Income Tax Expense
79,621
 
 
75,111
 
 
39,344
 
Pretax Income
$
235,268
 
 
$
252,615
 
 
$
157,801
 
 
 
 
 
 
 
Income Taxes on Pretax Income at Statutory Rate (35%)
$
82,344
 
 
$
88,415
 
 
$
55,230
 
Increase (Decrease) in Income Taxes Resulting from the Following Items:
 
 
 
 
 
Depreciation
12,885
 
 
10,057
 
 
8,659
 
Investment Tax Credits, Net
(4,877
)
 
(4,931
)
 
(4,502
)
State and Local Income Taxes, Net
7,668
 
 
(882
)
 
(1,559
)
Removal Costs
(11,272
)
 
(9,432
)
 
(5,490
)
AFUDC
(9,994
)
 
(10,555
)
 
(7,218
)
Other
2,867
 
 
2,439
 
 
(5,776
)
Income Tax Expense
$
79,621
 
 
$
75,111
 
 
$
39,344
 
 
 
 
 
 
 
Effective Income Tax Rate
33.8

%

 
29.7

%

 
24.9

%


OPCo
Years Ended December 31,
 
2014
 
2013
 
2012
 
(in thousands)
Net Income
$
216,422
 
 
$
409,980
 
 
$
343,534
 
Income Tax Expense
132,207
 
 
225,670
 
 
144,283
 
Pretax Income
$
348,629
 
 
$
635,650
 
 
$
487,817
 
 
 
 
 
 
 
Income Taxes on Pretax Income at Statutory Rate (35%)
$
122,020
 
 
$
222,478
 
 
$
170,736
 
Increase (Decrease) in Income Taxes Resulting from the Following Items:
 
 
 
 
 
Depreciation
6,665
 
 
6,759
 
 
5,239
 
Investment Tax Credits, Net
(241
)
 
(1,418
)
 
(1,849
)
State and Local Income Taxes, Net
8,866
 
 
3,327
 
 
(18,291
)
Parent Company Loss Benefit
(996
)
 
(2,154
)
 
(11,915
)
Other
(4,107
)
 
(3,322
)
 
363
 
Income Tax Expense
$
132,207
 
 
$
225,670
 
 
$
144,283
 
 
 
 
 
 
 
Effective Income Tax Rate
37.9

%

 
35.5

%

 
29.6

%


PSO
Years Ended December 31,
 
2014
 
2013
 
2012
 
(in thousands)
Net Income
$
86,929
 
 
$
97,796
 
 
$
114,141
 
Income Tax Expense
50,582
 
 
65,885
 
 
66,694
 
Pretax Income
$
137,511
 
 
$
163,681
 
 
$
180,835
 
 
 
 
 
 
 
Income Taxes on Pretax Income at Statutory Rate (35%)
$
48,129
 
 
$
57,288
 
 
$
63,292
 
Increase (Decrease) in Income Taxes Resulting from the Following Items:
 
 
 
 
 
Depreciation
176
 
 
164
 
 
(10
)
Investment Tax Credits, Net
(770
)
 
(776
)
 
(781
)
State and Local Income Taxes, Net
4,777
 
 
5,423
 
 
6,953
 
Tax Adjustments
(1,241
)
 
5,268
 
 
201
 
Other
(489
)
 
(1,482
)
 
(2,961
)
Income Tax Expense
$
50,582
 
 
$
65,885
 
 
$
66,694
 
 
 
 
 
 
 
Effective Income Tax Rate
36.8

%

 
40.3

%

 
36.9

%


SWEPCo
Years Ended December 31,
 
2014
 
2013
 
2012
 
(in thousands)
Net Income
$
144,559
 
 
$
153,819
 
 
$
202,513
 
Income Tax Expense
66,420
 
 
69,461
 
 
45,858
 
Pretax Income
$
210,979
 
 
$
223,280
 
 
$
248,371
 
 
 
 
 
 
 
Income Taxes on Pretax Income at Statutory Rate (35%)
$
73,843
 
 
$
78,148
 
 
$
86,930
 
Increase (Decrease) in Income Taxes Resulting from the Following Items:
 
 
 
 
 
Depreciation
2,944
 
 
3,086
 
 
2,105
 
Depletion
(4,143
)
 
(3,472
)
 
(3,276
)
Investment Tax Credits, Net
(1,377
)
 
(1,561
)
 
(550
)
State and Local Income Taxes, Net
3,083
 
 
(1,453
)
 
(18,010
)
AFUDC
(4,182
)
 
(2,381
)
 
(19,879
)
Other
(3,748
)
 
(2,906
)
 
(1,462
)
Income Tax Expense
$
66,420
 
 
$
69,461
 
 
$
45,858
 
 
 
 
 
 
 
Effective Income Tax Rate
31.5

%

 
31.1

%

 
18.5

%



The following tables show elements of the net deferred tax liability and significant temporary differences for each Registrant Subsidiary:
APCo
December 31,
 
2014
 
2013
 
(in thousands)
Deferred Tax Assets
$
446,346

 
$
548,966

Deferred Tax Liabilities
(2,711,233
)
 
(2,788,306
)
Net Deferred Tax Liabilities
$
(2,264,887
)
 
$
(2,239,340
)
 
 
 
 
Property Related Temporary Differences
$
(1,801,885
)
 
$
(1,725,853
)
Amounts Due from Customers for Future Federal Income Taxes
(70,417
)
 
(94,775
)
Deferred State Income Taxes
(239,724
)
 
(246,247
)
Regulatory Assets
(113,671
)
 
(104,824
)
Securitized Assets
(122,559
)
 
(130,834
)
Deferred Income Taxes on Other Comprehensive Loss
(2,710
)
 
(1,589
)
Net Operating Loss Carryforward
9,796

 
45,177

Tax Credit Carryforward
46,162

 
21,940

Valuation Allowance

 
(41,277
)
All Other, Net
30,121

 
38,942

Net Deferred Tax Liabilities
$
(2,264,887
)
 
$
(2,239,340
)

I&M
December 31,
 
2014
 
2013
 
(in thousands)
Deferred Tax Assets
$
911,811

 
$
843,630

Deferred Tax Liabilities
(2,190,002
)
 
(2,043,810
)
Net Deferred Tax Liabilities
$
(1,278,191
)
 
$
(1,200,180
)
 
 
 
 
Property Related Temporary Differences
$
(418,724
)
 
$
(390,829
)
Amounts Due from Customers for Future Federal Income Taxes
(40,580
)
 
(39,137
)
Deferred State Income Taxes
(138,907
)
 
(137,162
)
Deferred Income Taxes on Other Comprehensive Loss
7,732

 
8,351

Accrued Nuclear Decommissioning
(610,955
)
 
(553,794
)
Net Operating Loss Carryforward

 
15,690

Regulatory Assets
(74,690
)
 
(59,008
)
All Other, Net
(2,067
)
 
(44,291
)
Net Deferred Tax Liabilities
$
(1,278,191
)
 
$
(1,200,180
)

OPCo
December 31,
 
2014
 
2013
 
(in thousands)
Deferred Tax Assets
$
171,816

 
$
183,085

Deferred Tax Liabilities
(1,528,130
)
 
(1,477,691
)
Net Deferred Tax Liabilities
$
(1,356,314
)
 
$
(1,294,606
)
 
 
 
 
Property Related Temporary Differences
$
(926,520
)
 
$
(841,607
)
Amounts Due from Customers for Future Federal Income Taxes
(47,598
)
 
(51,946
)
Deferred State Income Taxes
(34,232
)
 
(28,569
)
Regulatory Assets
(242,391
)
 
(215,535
)
Deferred Income Taxes on Other Comprehensive Loss
(3,016
)
 
(3,812
)
Deferred Fuel and Purchased Power
(145,515
)
 
(176,192
)
All Other, Net
42,958

 
23,055

Net Deferred Tax Liabilities
$
(1,356,314
)
 
$
(1,294,606
)

PSO
December 31,
 
2014
 
2013
 
(in thousands)
Deferred Tax Assets
$
110,758

 
$
107,567

Deferred Tax Liabilities
(1,016,721
)
 
(936,791
)
Net Deferred Tax Liabilities
$
(905,963
)
 
$
(829,224
)
 
 
 
 
Property Related Temporary Differences
$
(805,193
)
 
$
(736,160
)
Amounts Due from Customers for Future Federal Income Taxes
(678
)
 
(31
)
Deferred State Income Taxes
(109,285
)
 
(99,126
)
Regulatory Assets
(39,620
)
 
(39,414
)
Deferred Income Taxes on Other Comprehensive Loss
(2,661
)
 
(3,100
)
Deferred Federal Income Taxes on Deferred State Income Taxes
43,918

 
40,362

Net Operating Loss Carryforward
6,365

 
4,314

Tax Credit Carryforward
681

 
565

All Other, Net
510

 
3,366

Net Deferred Tax Liabilities
$
(905,963
)
 
$
(829,224
)

SWEPCo
December 31,
 
2014
 
2013
 
(in thousands)
Deferred Tax Assets
$
186,176

 
$
359,529

Deferred Tax Liabilities
(1,528,246
)
 
(1,453,710
)
Net Deferred Tax Liabilities
$
(1,342,070
)
 
$
(1,094,181
)
 
 
 
 
Property Related Temporary Differences
$
(1,235,136
)
 
$
(1,172,431
)
Amounts Due from Customers for Future Federal Income Taxes
(44,119
)
 
(43,116
)
Deferred State Income Taxes
(124,147
)
 
(118,179
)
Regulatory Assets
(19,388
)
 
(5,290
)
Deferred Income Taxes on Other Comprehensive Loss
4,021

 
4,548

Impairment Loss - Turk Plant
21,052

 
21,295

Net Operating Loss Carryforward
21,925

 
189,128

All Other, Net
33,722

 
29,864

Net Deferred Tax Liabilities
$
(1,342,070
)
 
$
(1,094,181
)


AEP System Tax Allocation Agreement

The Registrant Subsidiaries join in the filing of a consolidated federal income tax return with their affiliates in the AEP System.  The allocation of the AEP System’s current consolidated federal income tax to the AEP System companies allocates the benefit of current tax losses to the AEP System companies giving rise to such losses in determining their current tax expense.  The tax benefit of the Parent is allocated to its subsidiaries with taxable income.  With the exception of the loss of the Parent, the method of allocation reflects a separate return result for each company in the consolidated group.

Federal and State Income Tax Audit Status

The Registrant Subsidiaries are no longer subject to U.S. federal examination for years before 2011.  The IRS examination of years 2011, 2012 and 2013 started in April 2014. Although the outcome of tax audits is uncertain, in management’s opinion, adequate provisions for federal income taxes have been made for potential liabilities resulting from such matters.  In addition, the Registrant Subsidiaries accrue interest on these uncertain tax positions.  Management is not aware of any issues for open tax years that upon final resolution are expected to materially impact net income.

The Registrant Subsidiaries file income tax returns in various state and local jurisdictions.  These taxing authorities routinely examine their tax returns and the Registrant Subsidiaries are currently under examination in several state and local jurisdictions.  However, it is possible that previously filed tax returns have positions that may be challenged by these tax authorities.  Management believes that adequate provisions for income taxes have been made for potential liabilities resulting from such challenges and that the ultimate resolution of these audits will not materially impact net income.  The Registrant Subsidiaries are no longer subject to state or local income tax examinations by tax authorities for years before 2009.

Net Income Tax Operating Loss Carryforward

In 2011, APCo and I&M recognized federal net income tax operating losses of $313 million and $123 million, respectively, driven primarily by bonus depreciation, pension plan contributions and other book versus tax temporary differences.  In 2012, SWEPCo recognized a federal net income tax operating loss of $858 million driven primarily by bonus depreciation.  APCo, OPCo, PSO and SWEPCo also have state net income tax operating loss carryforwards as indicated in the table below:
Company
 
State
 
State Net Income
Tax Operating
Loss
Carryforward
 
Year of
Expiration
 
 
 
 
(in thousands)
 
 
APCo
 
Tennessee
 
$
2,695

 
2026
APCo
 
West Virginia
 
235,341

 
2032
OPCo
 
West Virginia
 
50,228

 
2032
PSO
 
Oklahoma
 
163,212

 
2034
SWEPCo
 
Louisiana
 
419,384

 
2029
SWEPCo
 
Oklahoma
 
2,994

 
2034


As a result, APCo, OPCo, PSO and SWEPCo recognized deferred state and local income tax benefits in 2011, and/or 2012, and/or 2013 and/or 2014.  At the end of 2013, APCo, I&M and SWEPCo had $12 million, $13 million and $167 million, respectively, of unrealized federal net operating loss carryforward.  Federal taxable income was sufficient enough in 2014 that these remaining federal net income tax operating loss tax benefits were realized in full.  Management also anticipates future taxable income will be sufficient to realize the remaining state net income tax operating loss tax benefits before the state carryforward expires for each state.

Tax Credit Carryforward

Federal and state net income tax operating losses sustained in 2011 and 2009 along with lower federal and state taxable income in 2010 resulted in unused federal and state income tax credits.  As of December 31, 2014, the Registrant Subsidiaries have federal tax credit carryforwards and PSO has state tax credit carryforwards as indicated in the table below.  If these credits are not utilized, federal general business tax credits will expire in the years 2029 through 2033.
Company
 
Total Federal
Tax Credit
Carryforward
 
Federal Tax
Credit
Carryforward
Subject to
Expiration
 
Total State
Tax Credit
Carryforward
 
State Tax
Credit
Carryforward
Subject to
Expiration
 
 
(in thousands)
APCo
 
$
45,654

 
$
4,046

 
$

 
$

I&M
 
3,418

 
2,877

 

 

OPCo
 
25,679

 
1,962

 

 

PSO
 
681

 
660

 
22,141

 
22,141

SWEPCo
 
3,254

 
899

 

 



The Registrant Subsidiaries anticipate future federal taxable income will be sufficient to realize the tax benefits of the federal tax credits before they expire unused.  In November 2014, APCo received an order from the Virginia SCC for its 2014 Virginia Biennial Base Rate Case (see Note 4). As a result of the final determination pertaining to the ability to realize future tax benefits for certain state net income tax operating loss and credit carryforwards, management determined that APCo is subject to the Virginia Minimum Tax on electric suppliers and the Virginia State Income Tax is no longer applicable. As a result, management derecognized the related state income tax benefits, which had been subject to valuation allowances.

Uncertain Tax Positions

The Registrant Subsidiaries recognize interest accruals related to uncertain tax positions in interest income or expense as applicable and penalties in Other Operation expense in accordance with the accounting guidance for “Income Taxes.”

The following tables show amounts reported for interest expense, interest income and reversal of prior period interest expense:
 
 
Years Ended December 31,
 
 
2014
 
2013
Company
 
Interest
Expense
 
Interest
Income
 
Reversal of
Prior Period
Interest
Expense
 
Interest
Expense
 
Interest
Income
 
Reversal of
Prior Period
Interest
Expense
 
 
(in thousands)
APCo
 
$

 
$

 
$
193

 
$

 
$
1,089

 
$

I&M
 

 

 
289

 

 
597

 

OPCo
 
129

 

 
245

 

 
1,892

 

PSO
 
88

 

 
137

 

 
135

 

SWEPCo
 
172

 

 
154

 
215

 

 

 
 
Year Ended December 31, 2012
Company
 
Interest
Expense
 
Interest
Income
 
Reversal of
Prior Period
Interest
Expense
 
 
(in thousands)
APCo
 
$
62

 
$

 
$
183

I&M
 
1,355

 

 

OPCo
 
266

 

 
504

PSO
 
259

 

 
294

SWEPCo
 
286

 

 
271



The following table shows balances for amounts accrued for the receipt of interest:
 
 
December 31,
Company
 
2014
 
2013
 
 
(in thousands)
APCo
 
$

 
$

I&M
 

 

OPCo
 

 

PSO
 

 
209

SWEPCo
 

 
172



The following table shows balances for amounts accrued for the payment of interest and penalties:
 
 
December 31,
Company
 
2014
 
2013
 
 
(in thousands)
APCo
 
$

 
$
158

I&M
 
526

 
957

OPCo
 
382

 
407

PSO
 
310

 
562

SWEPCo
 
1,010

 
1,167



The reconciliations of the beginning and ending amounts of unrecognized tax benefits are as follows:
 
APCo
 
I&M
 
OPCo
 
PSO
 
SWEPCo
 
(in thousands)
Balance as of January 1, 2014
$
1,164

 
$
3,164

 
$
2,086

 
$
2,184

 
$
7,602

Increase  Tax Positions Taken During a Prior Period

 
1,431

 
6,335

 
64

 
1,602

Decrease  Tax Positions Taken During a Prior Period

 

 

 
(18
)
 
(832
)
Increase  Tax Positions Taken During the Current Year

 

 

 

 

Decrease  Tax Positions Taken During the Current Year

 

 

 

 

Increase  Settlements with Taxing Authorities
1

 

 
70

 
37

 

Decrease  Settlements with Taxing Authorities

 
(660
)
 

 

 
(30
)
Decrease  Lapse of the Applicable Statute of Limitations
(1,165
)
 
(1,640
)
 
(1,566
)
 
(948
)
 
(845
)
Balance as of December 31, 2014
$

 
$
2,295

 
$
6,925

 
$
1,319

 
$
7,497

 
APCo
 
I&M
 
OPCo
 
PSO
 
SWEPCo
 
(in thousands)
Balance as of January 1, 2013
$
5,253

 
$
15,085

 
$
11,052

 
$
2,273

 
$
9,553

Increase  Tax Positions Taken During a Prior Period

 

 

 

 

Decrease  Tax Positions Taken During a Prior Period
(4,089
)
 
(11,921
)
 
(8,966
)
 
(103
)
 
(3,158
)
Increase  Tax Positions Taken During the Current Year

 

 

 
14

 
1,301

Decrease  Tax Positions Taken During the Current Year

 

 

 

 

Decrease  Settlements with Taxing Authorities

 

 

 

 
(94
)
Decrease  Lapse of the Applicable Statute of Limitations

 

 

 

 

Balance as of December 31, 2013
$
1,164

 
$
3,164

 
$
2,086

 
$
2,184

 
$
7,602

 
APCo
 
I&M
 
OPCo
 
PSO
 
SWEPCo
 
(in thousands)
Balance as of January 1, 2012
$
7,311

 
$
14,071

 
$
43,565

 
$
3,585

 
$
9,031

Increase  Tax Positions Taken During a Prior Period

 
2,266

 
1,360

 
421

 
2,806

Decrease  Tax Positions Taken During a Prior Period
(384
)
 
(1,252
)
 
(13,582
)
 
(92
)
 
(775
)
Increase  Tax Positions Taken During the Current Year

 

 

 

 

Decrease  Tax Positions Taken During the Current Year

 

 

 

 

Decrease  Settlements with Taxing Authorities
(1,674
)
 

 
(20,291
)
 

 

Decrease  Lapse of the Applicable Statute of Limitations

 

 

 
(1,641
)
 
(1,509
)
Balance as of December 31, 2012
$
5,253

 
$
15,085

 
$
11,052

 
$
2,273

 
$
9,553



Management believes that there will be no significant net increase or decrease in unrecognized benefits within 12 months of the reporting date.  The total amount of unrecognized tax benefits that, if recognized, would affect the effective tax rate for each Registrant Subsidiary was as follows:
Company
 
2014
 
2013
 
2012
 
 
(in thousands)
APCo
 
$

 
$

 
$

I&M
 
1,591

 
1,220

 
1,220

OPCo
 
4,462

 
674

 
674

PSO
 
858

 
827

 
818

SWEPCo
 
4,873

 
4,357

 
3,512



Federal Tax Legislation – Affecting APCo, I&M, OPCo, PSO and SWEPCo

The American Taxpayer Relief Act of 2012 (the 2012 Act) was enacted in January 2013.  Included in the 2012 Act was a one-year extension of 50% bonus depreciation.  The 2012 Act also retroactively extended the life of research and development, employment and several energy tax credits, which expired at the end of 2011.  The enacted provisions did not materially impact the Registrant Subsidiaries’ net income or financial condition but did have a favorable impact on cash flows in 2013.

The Tax Increase Prevention Act of 2014 (the 2014 Act) was enacted in December 2014. Included in the 2014 Act was a one-year extension of the 50% bonus depreciation. The 2014 Act also retroactively extended the life of research and development, employment and several energy tax credits, which expired at the end of 2013. The enacted provisions did not materially impact the Registrant Subsidiaries' net income or financial condition but will have a favorable impact on future cash flows.

Federal Tax Regulations

In 2013, the U.S. Treasury Department issued final and re-proposed regulations regarding the deduction and capitalization of expenditures related to tangible property, effective for the tax years beginning in 2014.  In addition, the IRS issued Revenue Procedures under the Industry Issue Resolutions program that provides specific guidance for the implementation of the regulations for the electric utility industry.  These final regulations did not materially impact the Registrant Subsidiaries' net income, cash flows or financial condition.

State Tax Legislation – Affecting APCo, I&M and OPCo

Legislation was passed by the state of Indiana in May 2011 enacting a phased reduction in corporate income tax rate from 8.5% to 6.5%.  The 8.5% Indiana corporate income tax rate will be reduced 0.5% each year beginning after June 30, 2012 with the final reduction occurring in years beginning after June 30, 2015.

In May 2011, Michigan repealed its Business Tax regime and replaced it with a traditional corporate net income tax rate of 6%, effective January 1, 2012.

During the third quarter of 2013, it was determined that the state of West Virginia had achieved certain minimum levels of shortfall reserve funds.  As a result, the West Virginia corporate income tax rate was reduced from 7% to 6.5% in 2014.  

The enacted provisions did not materially impact the Registrant Subsidiaries’ net income, cash flows or financial condition.
Southwestern Electric Power Co [Member]  
Income Taxes
INCOME TAXES

The details of the Registrant Subsidiaries’ income taxes as reported are as follows:
Year Ended December 31, 2014
 
APCo
 
I&M
 
OPCo
 
PSO
 
SWEPCo
 
 
(in thousands)
Income Tax Expense (Credit):
 
 
 
 
 
 
 
 
 
 
Current
 
$
10,926

 
$
14,273

 
$
58,057

 
$
(24,349
)
 
$
(171,629
)
Deferred
 
144,651

 
70,225

 
74,391

 
74,756

 
239,426

Deferred Investment Tax Credits
 
(649
)
 
(4,877
)
 
(241
)
 
175

 
(1,377
)
Income Tax Expense
 
$
154,928

 
$
79,621

 
$
132,207

 
$
50,582

 
$
66,420

Year Ended December 31, 2013
 
APCo
 
I&M
 
OPCo
 
PSO
 
SWEPCo
 
 
(in thousands)
Income Tax Expense (Credit):
 
 
 
 
 
 
 
 
 
 
Current
 
$
58,441

 
$
(49,067
)
 
$
92,625

 
$
7,689

 
$
(10,866
)
Deferred
 
75,714

 
129,109

 
134,463

 
53,788

 
81,888

Deferred Investment Tax Credits
 
(1,220
)
 
(4,931
)
 
(1,418
)
 
4,408

 
(1,561
)
Income Tax Expense
 
$
132,935

 
$
75,111

 
$
225,670

 
$
65,885

 
$
69,461

Year Ended December 31, 2012
 
APCo
 
I&M
 
OPCo
 
PSO
 
SWEPCo
 
 
(in thousands)
Income Tax Expense (Credit):
 
 
 
 
 
 
 
 
 
 
Current
 
$
28,307

 
$
(9,221
)
 
$
100,447

 
$
18,634

 
$
(214,353
)
Deferred
 
138,460

 
53,067

 
45,685

 
48,916

 
260,761

Deferred Investment Tax Credits
 
(1,240
)
 
(4,502
)
 
(1,849
)
 
(856
)
 
(550
)
Income Tax Expense
 
$
165,527

 
$
39,344

 
$
144,283

 
$
66,694

 
$
45,858



Shown below for each Registrant Subsidiary is a reconciliation of the difference between the amounts of federal income taxes computed by multiplying book income before income taxes by the federal statutory tax rate and the amount of income taxes reported:
APCo
Years Ended December 31,
 
2014
 
2013
 
2012
 
(in thousands)
Net Income
$
215,415
 
 
$
193,211
 
 
$
257,503
 
Income Tax Expense
154,928
 
 
132,935
 
 
165,527
 
Pretax Income
$
370,343
 
 
$
326,146
 
 
$
423,030
 
 
 
 
 
 
 
Income Taxes on Pretax Income at Statutory Rate (35%)
$
129,620
 
 
$
114,151
 
 
$
148,061
 
Increase (Decrease) in Income Taxes Resulting from the Following Items:
 
 
 
 
 
Depreciation
23,527
 
 
20,286
 
 
20,424
 
Investment Tax Credits, Net
(649
)
 
(1,220
)
 
(1,240
)
State and Local Income Taxes, Net
6,531
 
 
2,707
 
 
3,175
 
Removal Costs
(6,844
)
 
(6,454
)
 
(6,641
)
AFUDC
(3,768
)
 
(1,420
)
 
(1,145
)
Valuation Allowance
(2,498
)
 
5,062
 
 
5,674
 
Other
9,009
 
 
(177
)
 
(2,781
)
Income Tax Expense
$
154,928
 
 
$
132,935
 
 
$
165,527
 
 
 
 
 
 
 
Effective Income Tax Rate
41.8

%

 
40.8

%

 
39.1

%

I&M
Years Ended December 31,
 
2014
 
2013
 
2012
 
(in thousands)
Net Income
$
155,647
 
 
$
177,504
 
 
$
118,457
 
Income Tax Expense
79,621
 
 
75,111
 
 
39,344
 
Pretax Income
$
235,268
 
 
$
252,615
 
 
$
157,801
 
 
 
 
 
 
 
Income Taxes on Pretax Income at Statutory Rate (35%)
$
82,344
 
 
$
88,415
 
 
$
55,230
 
Increase (Decrease) in Income Taxes Resulting from the Following Items:
 
 
 
 
 
Depreciation
12,885
 
 
10,057
 
 
8,659
 
Investment Tax Credits, Net
(4,877
)
 
(4,931
)
 
(4,502
)
State and Local Income Taxes, Net
7,668
 
 
(882
)
 
(1,559
)
Removal Costs
(11,272
)
 
(9,432
)
 
(5,490
)
AFUDC
(9,994
)
 
(10,555
)
 
(7,218
)
Other
2,867
 
 
2,439
 
 
(5,776
)
Income Tax Expense
$
79,621
 
 
$
75,111
 
 
$
39,344
 
 
 
 
 
 
 
Effective Income Tax Rate
33.8

%

 
29.7

%

 
24.9

%


OPCo
Years Ended December 31,
 
2014
 
2013
 
2012
 
(in thousands)
Net Income
$
216,422
 
 
$
409,980
 
 
$
343,534
 
Income Tax Expense
132,207
 
 
225,670
 
 
144,283
 
Pretax Income
$
348,629
 
 
$
635,650
 
 
$
487,817
 
 
 
 
 
 
 
Income Taxes on Pretax Income at Statutory Rate (35%)
$
122,020
 
 
$
222,478
 
 
$
170,736
 
Increase (Decrease) in Income Taxes Resulting from the Following Items:
 
 
 
 
 
Depreciation
6,665
 
 
6,759
 
 
5,239
 
Investment Tax Credits, Net
(241
)
 
(1,418
)
 
(1,849
)
State and Local Income Taxes, Net
8,866
 
 
3,327
 
 
(18,291
)
Parent Company Loss Benefit
(996
)
 
(2,154
)
 
(11,915
)
Other
(4,107
)
 
(3,322
)
 
363
 
Income Tax Expense
$
132,207
 
 
$
225,670
 
 
$
144,283
 
 
 
 
 
 
 
Effective Income Tax Rate
37.9

%

 
35.5

%

 
29.6

%


PSO
Years Ended December 31,
 
2014
 
2013
 
2012
 
(in thousands)
Net Income
$
86,929
 
 
$
97,796
 
 
$
114,141
 
Income Tax Expense
50,582
 
 
65,885
 
 
66,694
 
Pretax Income
$
137,511
 
 
$
163,681
 
 
$
180,835
 
 
 
 
 
 
 
Income Taxes on Pretax Income at Statutory Rate (35%)
$
48,129
 
 
$
57,288
 
 
$
63,292
 
Increase (Decrease) in Income Taxes Resulting from the Following Items:
 
 
 
 
 
Depreciation
176
 
 
164
 
 
(10
)
Investment Tax Credits, Net
(770
)
 
(776
)
 
(781
)
State and Local Income Taxes, Net
4,777
 
 
5,423
 
 
6,953
 
Tax Adjustments
(1,241
)
 
5,268
 
 
201
 
Other
(489
)
 
(1,482
)
 
(2,961
)
Income Tax Expense
$
50,582
 
 
$
65,885
 
 
$
66,694
 
 
 
 
 
 
 
Effective Income Tax Rate
36.8

%

 
40.3

%

 
36.9

%


SWEPCo
Years Ended December 31,
 
2014
 
2013
 
2012
 
(in thousands)
Net Income
$
144,559
 
 
$
153,819
 
 
$
202,513
 
Income Tax Expense
66,420
 
 
69,461
 
 
45,858
 
Pretax Income
$
210,979
 
 
$
223,280
 
 
$
248,371
 
 
 
 
 
 
 
Income Taxes on Pretax Income at Statutory Rate (35%)
$
73,843
 
 
$
78,148
 
 
$
86,930
 
Increase (Decrease) in Income Taxes Resulting from the Following Items:
 
 
 
 
 
Depreciation
2,944
 
 
3,086
 
 
2,105
 
Depletion
(4,143
)
 
(3,472
)
 
(3,276
)
Investment Tax Credits, Net
(1,377
)
 
(1,561
)
 
(550
)
State and Local Income Taxes, Net
3,083
 
 
(1,453
)
 
(18,010
)
AFUDC
(4,182
)
 
(2,381
)
 
(19,879
)
Other
(3,748
)
 
(2,906
)
 
(1,462
)
Income Tax Expense
$
66,420
 
 
$
69,461
 
 
$
45,858
 
 
 
 
 
 
 
Effective Income Tax Rate
31.5

%

 
31.1

%

 
18.5

%



The following tables show elements of the net deferred tax liability and significant temporary differences for each Registrant Subsidiary:
APCo
December 31,
 
2014
 
2013
 
(in thousands)
Deferred Tax Assets
$
446,346

 
$
548,966

Deferred Tax Liabilities
(2,711,233
)
 
(2,788,306
)
Net Deferred Tax Liabilities
$
(2,264,887
)
 
$
(2,239,340
)
 
 
 
 
Property Related Temporary Differences
$
(1,801,885
)
 
$
(1,725,853
)
Amounts Due from Customers for Future Federal Income Taxes
(70,417
)
 
(94,775
)
Deferred State Income Taxes
(239,724
)
 
(246,247
)
Regulatory Assets
(113,671
)
 
(104,824
)
Securitized Assets
(122,559
)
 
(130,834
)
Deferred Income Taxes on Other Comprehensive Loss
(2,710
)
 
(1,589
)
Net Operating Loss Carryforward
9,796

 
45,177

Tax Credit Carryforward
46,162

 
21,940

Valuation Allowance

 
(41,277
)
All Other, Net
30,121

 
38,942

Net Deferred Tax Liabilities
$
(2,264,887
)
 
$
(2,239,340
)

I&M
December 31,
 
2014
 
2013
 
(in thousands)
Deferred Tax Assets
$
911,811

 
$
843,630

Deferred Tax Liabilities
(2,190,002
)
 
(2,043,810
)
Net Deferred Tax Liabilities
$
(1,278,191
)
 
$
(1,200,180
)
 
 
 
 
Property Related Temporary Differences
$
(418,724
)
 
$
(390,829
)
Amounts Due from Customers for Future Federal Income Taxes
(40,580
)
 
(39,137
)
Deferred State Income Taxes
(138,907
)
 
(137,162
)
Deferred Income Taxes on Other Comprehensive Loss
7,732

 
8,351

Accrued Nuclear Decommissioning
(610,955
)
 
(553,794
)
Net Operating Loss Carryforward

 
15,690

Regulatory Assets
(74,690
)
 
(59,008
)
All Other, Net
(2,067
)
 
(44,291
)
Net Deferred Tax Liabilities
$
(1,278,191
)
 
$
(1,200,180
)

OPCo
December 31,
 
2014
 
2013
 
(in thousands)
Deferred Tax Assets
$
171,816

 
$
183,085

Deferred Tax Liabilities
(1,528,130
)
 
(1,477,691
)
Net Deferred Tax Liabilities
$
(1,356,314
)
 
$
(1,294,606
)
 
 
 
 
Property Related Temporary Differences
$
(926,520
)
 
$
(841,607
)
Amounts Due from Customers for Future Federal Income Taxes
(47,598
)
 
(51,946
)
Deferred State Income Taxes
(34,232
)
 
(28,569
)
Regulatory Assets
(242,391
)
 
(215,535
)
Deferred Income Taxes on Other Comprehensive Loss
(3,016
)
 
(3,812
)
Deferred Fuel and Purchased Power
(145,515
)
 
(176,192
)
All Other, Net
42,958

 
23,055

Net Deferred Tax Liabilities
$
(1,356,314
)
 
$
(1,294,606
)

PSO
December 31,
 
2014
 
2013
 
(in thousands)
Deferred Tax Assets
$
110,758

 
$
107,567

Deferred Tax Liabilities
(1,016,721
)
 
(936,791
)
Net Deferred Tax Liabilities
$
(905,963
)
 
$
(829,224
)
 
 
 
 
Property Related Temporary Differences
$
(805,193
)
 
$
(736,160
)
Amounts Due from Customers for Future Federal Income Taxes
(678
)
 
(31
)
Deferred State Income Taxes
(109,285
)
 
(99,126
)
Regulatory Assets
(39,620
)
 
(39,414
)
Deferred Income Taxes on Other Comprehensive Loss
(2,661
)
 
(3,100
)
Deferred Federal Income Taxes on Deferred State Income Taxes
43,918

 
40,362

Net Operating Loss Carryforward
6,365

 
4,314

Tax Credit Carryforward
681

 
565

All Other, Net
510

 
3,366

Net Deferred Tax Liabilities
$
(905,963
)
 
$
(829,224
)

SWEPCo
December 31,
 
2014
 
2013
 
(in thousands)
Deferred Tax Assets
$
186,176

 
$
359,529

Deferred Tax Liabilities
(1,528,246
)
 
(1,453,710
)
Net Deferred Tax Liabilities
$
(1,342,070
)
 
$
(1,094,181
)
 
 
 
 
Property Related Temporary Differences
$
(1,235,136
)
 
$
(1,172,431
)
Amounts Due from Customers for Future Federal Income Taxes
(44,119
)
 
(43,116
)
Deferred State Income Taxes
(124,147
)
 
(118,179
)
Regulatory Assets
(19,388
)
 
(5,290
)
Deferred Income Taxes on Other Comprehensive Loss
4,021

 
4,548

Impairment Loss - Turk Plant
21,052

 
21,295

Net Operating Loss Carryforward
21,925

 
189,128

All Other, Net
33,722

 
29,864

Net Deferred Tax Liabilities
$
(1,342,070
)
 
$
(1,094,181
)


AEP System Tax Allocation Agreement

The Registrant Subsidiaries join in the filing of a consolidated federal income tax return with their affiliates in the AEP System.  The allocation of the AEP System’s current consolidated federal income tax to the AEP System companies allocates the benefit of current tax losses to the AEP System companies giving rise to such losses in determining their current tax expense.  The tax benefit of the Parent is allocated to its subsidiaries with taxable income.  With the exception of the loss of the Parent, the method of allocation reflects a separate return result for each company in the consolidated group.

Federal and State Income Tax Audit Status

The Registrant Subsidiaries are no longer subject to U.S. federal examination for years before 2011.  The IRS examination of years 2011, 2012 and 2013 started in April 2014. Although the outcome of tax audits is uncertain, in management’s opinion, adequate provisions for federal income taxes have been made for potential liabilities resulting from such matters.  In addition, the Registrant Subsidiaries accrue interest on these uncertain tax positions.  Management is not aware of any issues for open tax years that upon final resolution are expected to materially impact net income.

The Registrant Subsidiaries file income tax returns in various state and local jurisdictions.  These taxing authorities routinely examine their tax returns and the Registrant Subsidiaries are currently under examination in several state and local jurisdictions.  However, it is possible that previously filed tax returns have positions that may be challenged by these tax authorities.  Management believes that adequate provisions for income taxes have been made for potential liabilities resulting from such challenges and that the ultimate resolution of these audits will not materially impact net income.  The Registrant Subsidiaries are no longer subject to state or local income tax examinations by tax authorities for years before 2009.

Net Income Tax Operating Loss Carryforward

In 2011, APCo and I&M recognized federal net income tax operating losses of $313 million and $123 million, respectively, driven primarily by bonus depreciation, pension plan contributions and other book versus tax temporary differences.  In 2012, SWEPCo recognized a federal net income tax operating loss of $858 million driven primarily by bonus depreciation.  APCo, OPCo, PSO and SWEPCo also have state net income tax operating loss carryforwards as indicated in the table below:
Company
 
State
 
State Net Income
Tax Operating
Loss
Carryforward
 
Year of
Expiration
 
 
 
 
(in thousands)
 
 
APCo
 
Tennessee
 
$
2,695

 
2026
APCo
 
West Virginia
 
235,341

 
2032
OPCo
 
West Virginia
 
50,228

 
2032
PSO
 
Oklahoma
 
163,212

 
2034
SWEPCo
 
Louisiana
 
419,384

 
2029
SWEPCo
 
Oklahoma
 
2,994

 
2034


As a result, APCo, OPCo, PSO and SWEPCo recognized deferred state and local income tax benefits in 2011, and/or 2012, and/or 2013 and/or 2014.  At the end of 2013, APCo, I&M and SWEPCo had $12 million, $13 million and $167 million, respectively, of unrealized federal net operating loss carryforward.  Federal taxable income was sufficient enough in 2014 that these remaining federal net income tax operating loss tax benefits were realized in full.  Management also anticipates future taxable income will be sufficient to realize the remaining state net income tax operating loss tax benefits before the state carryforward expires for each state.

Tax Credit Carryforward

Federal and state net income tax operating losses sustained in 2011 and 2009 along with lower federal and state taxable income in 2010 resulted in unused federal and state income tax credits.  As of December 31, 2014, the Registrant Subsidiaries have federal tax credit carryforwards and PSO has state tax credit carryforwards as indicated in the table below.  If these credits are not utilized, federal general business tax credits will expire in the years 2029 through 2033.
Company
 
Total Federal
Tax Credit
Carryforward
 
Federal Tax
Credit
Carryforward
Subject to
Expiration
 
Total State
Tax Credit
Carryforward
 
State Tax
Credit
Carryforward
Subject to
Expiration
 
 
(in thousands)
APCo
 
$
45,654

 
$
4,046

 
$

 
$

I&M
 
3,418

 
2,877

 

 

OPCo
 
25,679

 
1,962

 

 

PSO
 
681

 
660

 
22,141

 
22,141

SWEPCo
 
3,254

 
899

 

 



The Registrant Subsidiaries anticipate future federal taxable income will be sufficient to realize the tax benefits of the federal tax credits before they expire unused.  In November 2014, APCo received an order from the Virginia SCC for its 2014 Virginia Biennial Base Rate Case (see Note 4). As a result of the final determination pertaining to the ability to realize future tax benefits for certain state net income tax operating loss and credit carryforwards, management determined that APCo is subject to the Virginia Minimum Tax on electric suppliers and the Virginia State Income Tax is no longer applicable. As a result, management derecognized the related state income tax benefits, which had been subject to valuation allowances.

Uncertain Tax Positions

The Registrant Subsidiaries recognize interest accruals related to uncertain tax positions in interest income or expense as applicable and penalties in Other Operation expense in accordance with the accounting guidance for “Income Taxes.”

The following tables show amounts reported for interest expense, interest income and reversal of prior period interest expense:
 
 
Years Ended December 31,
 
 
2014
 
2013
Company
 
Interest
Expense
 
Interest
Income
 
Reversal of
Prior Period
Interest
Expense
 
Interest
Expense
 
Interest
Income
 
Reversal of
Prior Period
Interest
Expense
 
 
(in thousands)
APCo
 
$

 
$

 
$
193

 
$

 
$
1,089

 
$

I&M
 

 

 
289

 

 
597

 

OPCo
 
129

 

 
245

 

 
1,892

 

PSO
 
88

 

 
137

 

 
135

 

SWEPCo
 
172

 

 
154

 
215

 

 

 
 
Year Ended December 31, 2012
Company
 
Interest
Expense
 
Interest
Income
 
Reversal of
Prior Period
Interest
Expense
 
 
(in thousands)
APCo
 
$
62

 
$

 
$
183

I&M
 
1,355

 

 

OPCo
 
266

 

 
504

PSO
 
259

 

 
294

SWEPCo
 
286

 

 
271



The following table shows balances for amounts accrued for the receipt of interest:
 
 
December 31,
Company
 
2014
 
2013
 
 
(in thousands)
APCo
 
$

 
$

I&M
 

 

OPCo
 

 

PSO
 

 
209

SWEPCo
 

 
172



The following table shows balances for amounts accrued for the payment of interest and penalties:
 
 
December 31,
Company
 
2014
 
2013
 
 
(in thousands)
APCo
 
$

 
$
158

I&M
 
526

 
957

OPCo
 
382

 
407

PSO
 
310

 
562

SWEPCo
 
1,010

 
1,167



The reconciliations of the beginning and ending amounts of unrecognized tax benefits are as follows:
 
APCo
 
I&M
 
OPCo
 
PSO
 
SWEPCo
 
(in thousands)
Balance as of January 1, 2014
$
1,164

 
$
3,164

 
$
2,086

 
$
2,184

 
$
7,602

Increase  Tax Positions Taken During a Prior Period

 
1,431

 
6,335

 
64

 
1,602

Decrease  Tax Positions Taken During a Prior Period

 

 

 
(18
)
 
(832
)
Increase  Tax Positions Taken During the Current Year

 

 

 

 

Decrease  Tax Positions Taken During the Current Year

 

 

 

 

Increase  Settlements with Taxing Authorities
1

 

 
70

 
37

 

Decrease  Settlements with Taxing Authorities

 
(660
)
 

 

 
(30
)
Decrease  Lapse of the Applicable Statute of Limitations
(1,165
)
 
(1,640
)
 
(1,566
)
 
(948
)
 
(845
)
Balance as of December 31, 2014
$

 
$
2,295

 
$
6,925

 
$
1,319

 
$
7,497

 
APCo
 
I&M
 
OPCo
 
PSO
 
SWEPCo
 
(in thousands)
Balance as of January 1, 2013
$
5,253

 
$
15,085

 
$
11,052

 
$
2,273

 
$
9,553

Increase  Tax Positions Taken During a Prior Period

 

 

 

 

Decrease  Tax Positions Taken During a Prior Period
(4,089
)
 
(11,921
)
 
(8,966
)
 
(103
)
 
(3,158
)
Increase  Tax Positions Taken During the Current Year

 

 

 
14

 
1,301

Decrease  Tax Positions Taken During the Current Year

 

 

 

 

Decrease  Settlements with Taxing Authorities

 

 

 

 
(94
)
Decrease  Lapse of the Applicable Statute of Limitations

 

 

 

 

Balance as of December 31, 2013
$
1,164

 
$
3,164

 
$
2,086

 
$
2,184

 
$
7,602

 
APCo
 
I&M
 
OPCo
 
PSO
 
SWEPCo
 
(in thousands)
Balance as of January 1, 2012
$
7,311

 
$
14,071

 
$
43,565

 
$
3,585

 
$
9,031

Increase  Tax Positions Taken During a Prior Period

 
2,266

 
1,360

 
421

 
2,806

Decrease  Tax Positions Taken During a Prior Period
(384
)
 
(1,252
)
 
(13,582
)
 
(92
)
 
(775
)
Increase  Tax Positions Taken During the Current Year

 

 

 

 

Decrease  Tax Positions Taken During the Current Year

 

 

 

 

Decrease  Settlements with Taxing Authorities
(1,674
)
 

 
(20,291
)
 

 

Decrease  Lapse of the Applicable Statute of Limitations

 

 

 
(1,641
)
 
(1,509
)
Balance as of December 31, 2012
$
5,253

 
$
15,085

 
$
11,052

 
$
2,273

 
$
9,553



Management believes that there will be no significant net increase or decrease in unrecognized benefits within 12 months of the reporting date.  The total amount of unrecognized tax benefits that, if recognized, would affect the effective tax rate for each Registrant Subsidiary was as follows:
Company
 
2014
 
2013
 
2012
 
 
(in thousands)
APCo
 
$

 
$

 
$

I&M
 
1,591

 
1,220

 
1,220

OPCo
 
4,462

 
674

 
674

PSO
 
858

 
827

 
818

SWEPCo
 
4,873

 
4,357

 
3,512



Federal Tax Legislation – Affecting APCo, I&M, OPCo, PSO and SWEPCo

The American Taxpayer Relief Act of 2012 (the 2012 Act) was enacted in January 2013.  Included in the 2012 Act was a one-year extension of 50% bonus depreciation.  The 2012 Act also retroactively extended the life of research and development, employment and several energy tax credits, which expired at the end of 2011.  The enacted provisions did not materially impact the Registrant Subsidiaries’ net income or financial condition but did have a favorable impact on cash flows in 2013.

The Tax Increase Prevention Act of 2014 (the 2014 Act) was enacted in December 2014. Included in the 2014 Act was a one-year extension of the 50% bonus depreciation. The 2014 Act also retroactively extended the life of research and development, employment and several energy tax credits, which expired at the end of 2013. The enacted provisions did not materially impact the Registrant Subsidiaries' net income or financial condition but will have a favorable impact on future cash flows.

Federal Tax Regulations

In 2013, the U.S. Treasury Department issued final and re-proposed regulations regarding the deduction and capitalization of expenditures related to tangible property, effective for the tax years beginning in 2014.  In addition, the IRS issued Revenue Procedures under the Industry Issue Resolutions program that provides specific guidance for the implementation of the regulations for the electric utility industry.  These final regulations did not materially impact the Registrant Subsidiaries' net income, cash flows or financial condition.

State Tax Legislation – Affecting APCo, I&M and OPCo

Legislation was passed by the state of Indiana in May 2011 enacting a phased reduction in corporate income tax rate from 8.5% to 6.5%.  The 8.5% Indiana corporate income tax rate will be reduced 0.5% each year beginning after June 30, 2012 with the final reduction occurring in years beginning after June 30, 2015.

In May 2011, Michigan repealed its Business Tax regime and replaced it with a traditional corporate net income tax rate of 6%, effective January 1, 2012.

During the third quarter of 2013, it was determined that the state of West Virginia had achieved certain minimum levels of shortfall reserve funds.  As a result, the West Virginia corporate income tax rate was reduced from 7% to 6.5% in 2014.  

The enacted provisions did not materially impact the Registrant Subsidiaries’ net income, cash flows or financial condition.