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Income Taxes
6 Months Ended
Jun. 30, 2011
Income Tax Disclosure [Abstract]  
Income Taxes

12. Income Taxes

The Company is under continuous examination by the Internal Revenue Service (IRS) and tax authorities in other countries and states in which the Company has significant business operations. The tax years under examination and open for examination vary by jurisdiction. In June 2008, the IRS completed its field examination of the Company's federal tax returns for the years 1997 through 2002. In July 2009, the IRS completed its field examination of the Company's federal tax returns for the years 2003 and 2004. In April 2011, unagreed issues for 1997 through 2004 were resolved at IRS Appeals. Additional refund claims for those years continue to be reviewed by the IRS. In addition, the Company is currently under examination by the IRS for the years 2005 through 2007.

 

The Company believes it is reasonably possible that the unrecognized tax benefits could decrease within the next 12 months by as much as $679 million principally as a result of potential resolutions of prior years' tax items with various taxing authorities. The prior years' tax items include unrecognized tax benefits relating to the deductibility of certain expenses or losses and the attribution of taxable income to a particular jurisdiction or jurisdictions. Of the $679 million of unrecognized tax benefits, approximately $452 million relates to amounts recorded to equity that, if recognized, would not impact the effective tax rate. With respect to the remaining $227 million, it is not possible to quantify the impact that the decrease could have on the effective tax rate and net income due to the inherent complexities and the number of tax years open for examination in multiple jurisdictions.  Resolution of the prior years' items that comprise this remaining amount could have an impact on the effective tax rate and on net income, either favorably (principally as a result of settlements that are less than the liability for unrecognized tax benefits) or unfavorably (if such settlements exceed the liability for unrecognized tax benefits).

 

The following table summarizes the Company's effective tax rate from continuing operations:

  Three Months Ended  Six Months Ended  Year Ended 
  June 30, 2011  June 30, 2011  December 31, 2010 
Effective tax rate(a)(b)  27  29 32

(a)       Each of the periods reflects recurring, permanent tax benefits in relation to the level of pretax income.

(a)       Each of the periods reflects recurring, permanent tax benefits in relation to the level of pretax income.

(b)       The income tax provision from continuing operations for the three and six months ended June 30, 2011 includes the impact of a $102 million tax benefit related to the favorable resolution of certain prior years' tax items.

Discontinued operations for the three and six months ended June 30, 2011 included the impact of a $36 million tax benefit related to the favorable resolution of certain prior years' tax items related to American Express Bank, Ltd., which was sold to Standard Chartered PLC during the quarter ended March 31, 2008.