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Income Taxes
12 Months Ended
Dec. 31, 2021
Income Taxes INCOME TAXES (Entergy Corporation, Entergy Arkansas, Entergy Louisiana, Entergy Mississippi, Entergy New Orleans, Entergy Texas, and System Energy)
Income taxes for 2021, 2020, and 2019 for Entergy Corporation and Subsidiaries consist of the following:
 202120202019
 (In Thousands)
Current:   
Federal($5,003)$5,807 ($14,416)
State(8,995)57,939 6,535 
Total(13,998)63,746 (7,881)
Deferred and non-current - net205,891 (190,635)(155,956)
Investment tax credit adjustments - net(519)5,383 (5,988)
Income taxes$191,374 ($121,506)($169,825)

Income taxes for 2021, 2020, and 2019 for Entergy’s Registrant Subsidiaries consist of the following:
2021Entergy ArkansasEntergy LouisianaEntergy MississippiEntergy New OrleansEntergy TexasSystem Energy
(In Thousands)
Current:      
Federal($20,285)($24,053)($5,868)($6,724)($189)$29,416 
State529 2,459 (11,506)(413)1,261 (10,258)
Total(19,756)(21,594)(17,374)(7,137)1,072 19,158 
Deferred and non-current - net96,180 146,786 60,861 12,870 25,087 (25,229)
Investment tax credit adjustments - net(1,229)(4,783)1,836 203 (633)4,094 
Income taxes$75,195 $120,409 $45,323 $5,936 $25,526 ($1,977)

2020Entergy ArkansasEntergy LouisianaEntergy MississippiEntergy New OrleansEntergy TexasSystem Energy
 (In Thousands)
Current:      
Federal($44,627)$62,728 ($14,580)$293 ($5,603)$372,206 
State(2,563)4,457 (1,316)(303)2,658 55,551 
Total(47,190)67,185 (15,896)(10)(2,945)427,757 
Deferred and non-current - net96,195 (444,647)43,640 (18,153)6,619 (405,928)
Investment tax credit adjustments - net(1,228)(4,862)(554)13,956 (632)(1,286)
Income taxes$47,777 ($382,324)$27,190 ($4,207)$3,042 $20,543 
2019Entergy ArkansasEntergy LouisianaEntergy MississippiEntergy New OrleansEntergy TexasSystem Energy
 (In Thousands)
Current:      
Federal($14,549)($20,173)($8,939)($5,822)$16,035 $16,256 
State(714)(735)5,823 1,856 663 (2,831)
Total(15,263)(20,908)(3,116)(3,966)16,698 13,425 
Deferred and non-current - net(30,278)147,453 34,579 4,248 (69,963)422 
Investment tax credit adjustments - net(1,228)(4,922)(597)(96)(631)1,502 
Income taxes($46,769)$121,623 $30,866 $186 ($53,896)$15,349 

Total income taxes for Entergy Corporation and Subsidiaries differ from the amounts computed by applying the statutory income tax rate to income before income taxes.  The reasons for the differences for the years 2021, 2020, and 2019 are:
 202120202019
 (In Thousands)
Net income attributable to Entergy Corporation$1,118,492 $1,388,334 $1,241,226 
Preferred dividend requirements of subsidiaries227 18,319 17,018 
Consolidated net income1,118,719 1,406,653 1,258,244 
Income taxes191,374 (121,506)(169,825)
Income before income taxes$1,310,093 $1,285,147 $1,088,419 
Computed at statutory rate (21%)$275,120 $269,881 $228,568 
Increases (reductions) in tax resulting from:   
State income taxes net of federal income tax effect79,273 60,087 61,791 
Regulatory differences - utility plant items(57,556)(53,229)(45,336)
Equity component of AFUDC(14,799)(25,080)(30,444)
Amortization of investment tax credits(7,695)(8,386)(8,093)
Flow-through / permanent differences(5,585)11,099 (2,059)
Amortization of excess ADIT (a)(66,478)(59,629)(205,614)
Arkansas and Louisiana Rate Changes (b)(27,108)— — 
IRS audit adjustment (d)— (301,041)— 
Entergy Wholesale Commodities restructuring (c)— (9,223)(173,725)
Stock compensation (e)— (25,591)— 
Charitable contribution (c)— — (19,101)
Net operating loss recognition— — (41,427)
Provision for uncertain tax positions16,533 15,208 7,332 
Valuation allowance(2,600)— 59,345 
Other - net2,269 4,398 (1,062)
Total income taxes as reported$191,374 ($121,506)($169,825)
Effective Income Tax Rate14.6 %(9.5 %)(15.6 %)

(a)See “Other Tax Matters - Tax Cuts and Jobs Act” below for discussion of the amortization of excess accumulated deferred income taxes (ADIT) in 2019, 2020, and 2021 and the tax legislation enactment in 2017.
(b)See “Arkansas and Louisiana Corporate Income Tax Rate Changes” below for details.
(c)See Other Tax Matters - Entergy Wholesale Commodities Restructuring” below for discussion of the Entergy Wholesale Commodities restructuring in 2019, the ownership of Palisades restructuring in 2020, and the charitable contribution in 2019.
(d)See “Income Tax Audits - 2014-2015 IRS Audit” below for discussion of the resolution of the audit in 2020.
(e)See “Other Tax Matters - Stock Compensation” below for discussion of excess tax deductions.

Total income taxes for the Registrant Subsidiaries differ from the amounts computed by applying the statutory income tax rate to income before taxes.  The reasons for the differences for the years 2021, 2020, and 2019 are:
2021Entergy ArkansasEntergy LouisianaEntergy MississippiEntergy New OrleansEntergy TexasSystem Energy
 (In Thousands)
Net income$298,484 $653,984 $166,834 $31,798 $228,824 $106,814 
Income taxes75,195 120,409 45,323 5,936 25,526 (1,977)
Pretax income$373,679 $774,393 $212,157 $37,734 $254,350 $104,837 
Computed at statutory rate (21%)$78,473 $162,623 $44,553 $7,924 $53,413 $22,016 
Increases (reductions) in tax resulting from:     
State income taxes net of federal income tax effect19,633 41,030 9,305 2,579 1,553 5,385 
Regulatory differences - utility plant items(16,078)(14,123)(8,133)(4,332)(2,115)(12,776)
Equity component of AFUDC(3,207)(6,016)(1,701)(498)(2,077)(1,300)
Amortization of investment tax credits(1,201)(4,729)64 (56)(617)(1,155)
Flow-through / permanent differences(814)(2,655)124 1,559 (475)(1,235)
Amortization of excess ADIT (a)(5,845)(24,323)— (1,028)(21,929)(13,354)
Arkansas and Louisiana Rate Changes (b)398 (6,126)395 (1,569)216 115 
Non-taxable dividend income— (26,801)— — — — 
Provision for uncertain tax positions353 300 465 1,200 (2,716)200 
Valuation Allowance2,766 — — — — — 
Other - net717 1,229 251 157 273 127 
Total income taxes as reported$75,195 $120,409 $45,323 $5,936 $25,526 ($1,977)
Effective Income Tax Rate20.1 %15.5 %21.4 %15.7 %10.0 %(1.9 %)
2020Entergy ArkansasEntergy LouisianaEntergy MississippiEntergy New OrleansEntergy TexasSystem Energy
 (In Thousands)
Net income$245,232 $1,082,352 $140,583 $49,338 $215,073 $99,131 
Income taxes47,777 (382,324)27,190 (4,207)3,042 20,543 
Pretax income$293,009 $700,028 $167,773 $45,131 $218,115 $119,674 
Computed at statutory rate (21%)$61,532 $147,006 $35,232 $9,478 $45,804 $25,132 
Increases (reductions) in tax resulting from:
State income taxes net of federal income tax effect16,256 38,182 6,917 2,606 1,460 5,524 
Regulatory differences - utility plant items(8,034)(23,819)(7,441)(3,442)(7,673)(2,821)
Equity component of AFUDC(3,154)(8,012)(1,412)(1,331)(9,255)(1,916)
Amortization of investment tax credits(1,201)(4,811)(540)(61)(617)(1,155)
Flow-through / permanent differences(2,219)1,404 (102)498 766 (421)
Amortization of excess ADIT (a)(6,011)(26,293)18 (4,564)(22,780)— 
Stock compensation (d)(4,952)(9,004)(2,763)(1,526)(2,842)(1,300)
IRS audit adjustment (c)(6,351)(471,702)(3,768)(6,819)(2,091)(2,925)
Non-taxable dividend income— (26,795)— — — — 
Provision for uncertain tax positions1,200 300 800 800 — 300 
Other - net711 1,220 249 154 270 125 
Total income taxes as reported$47,777 ($382,324)$27,190 ($4,207)$3,042 $20,543 
Effective Income Tax Rate16.3 %(54.6 %)16.2 %(9.3 %)1.4 %17.2 %

2019Entergy ArkansasEntergy LouisianaEntergy MississippiEntergy New OrleansEntergy TexasSystem Energy
 (In Thousands)
Net income$262,964 $691,537 $119,925 $52,629 $159,397 $99,120 
Income taxes(46,769)121,623 30,866 186 (53,896)15,349 
Pretax income$216,195 $813,160 $150,791 $52,815 $105,501 $114,469 
Computed at statutory rate (21%)$45,401 $170,764 $31,666 $11,091 $22,155 $24,039 
Increases (reductions) in tax resulting from:      
State income taxes net of federal income tax effect15,954 42,854 5,563 3,443 360 5,134 
Regulatory differences - utility plant items(10,627)(19,421)(5,556)(1,532)(1,987)(6,213)
Equity component of AFUDC(3,255)(15,545)(1,755)(2,088)(5,973)(1,829)
Amortization of investment tax credits(1,201)(4,871)(160)(88)(617)(1,155)
Flow-through / permanent differences696 439 160 (741)560 (500)
Amortization of excess ADIT (a)(90,921)(28,531)203 (11,724)(69,091)(5,550)
Non-taxable dividend income— (26,795)— — — — 
Provision for uncertain tax positions(3,517)1,519 500 1,672 430 1,300 
Other - net701 1,210 245 153 267 123 
Total income taxes as reported($46,769)$121,623 $30,866 $186 ($53,896)$15,349 
Effective Income Tax Rate(21.6 %)15.0 %20.5 %0.4 %(51.1 %)13.4 %
(a)See “Other Tax Matters - Tax Cuts and Jobs Act” below for discussion of the amortization of excess accumulated deferred income taxes (ADIT) in 2019, 2020 and 2021 and the tax legislation enactment in 2017.
(b)See “Arkansas and Louisiana Corporate Income Tax Rate Changes” below for details.
(c)See “Income Tax Audits - 2014-2015 IRS Audit” below for discussion of the resolution of the audit in 2020.
(d)See “Other Tax Matters - Stock Compensation” below for discussion of excess tax deductions.


Significant components of accumulated deferred income taxes and taxes accrued for Entergy Corporation and Subsidiaries as of December 31, 2021 and 2020 are as follows:
 
 20212020
 (In Thousands)
Deferred tax liabilities:  
Plant basis differences - net($6,136,563)($4,795,422)
Regulatory assets(930,244)(429,996)
Nuclear decommissioning trusts/receivables(656,185)(1,188,235)
Pension, net regulatory asset(322,788)(327,445)
Combined unitary state taxes(7,255)(7,723)
Unbilled/deferred revenues— (9,152)
Accumulated storm damage provision(207,243)— 
Deferred fuel(85,310)(7,667)
Other(341,450)(549,355)
Total(8,687,038)(7,314,995)
Deferred tax assets:  
Nuclear decommissioning liabilities278,136 968,464 
Regulatory liabilities1,318,381 791,927 
Pension and other post-employment benefits208,128 278,486 
Sale and leaseback102,474 102,477 
Compensation79,798 89,279 
Accumulated deferred investment tax credit57,986 57,379 
Provision for allowances and contingencies82,286 71,598 
Power purchase agreements55,259 352,019 
Unbilled/deferred revenues26,683 — 
Net operating loss carryforwards2,868,424 1,580,109 
Capital losses and miscellaneous tax credits11,111 21,291 
Valuation allowance(325,239)(328,581)
Other200,032 230,291 
Total4,963,459 4,214,739 
Non-current accrued taxes (including unrecognized tax benefits)(929,032)(1,185,227)
Accumulated deferred income taxes and taxes accrued($4,652,611)($4,285,483)
Entergy’s estimated tax attributes carryovers and their expiration dates as of December 31, 2021 are as follows:
Carryover DescriptionCarryover AmountYear(s) of expiration
   
Federal net operating losses before 1/1/2018$6.2 billion2023-2027
Federal net operating losses - 1/1/2018 forward$21.1 billionN/A
State net operating losses$7.4 billion2022-2041
State net operating losses with no expiration$16.7 billionN/A
Federal and state charitable contributions$460.8 million2022-2026
Miscellaneous federal and state credits$73.1 million2022-2041

As a result of the accounting for uncertain tax positions, the amount of the deferred tax assets reflected in the financial statements is less than the amount of the tax effect of the federal and state net operating loss carryovers, tax credit carryovers, and other tax attributes reflected on income tax returns. Entergy evaluates the available positive and negative evidence to estimate whether sufficient future taxable income of the appropriate character will be generated to realize the benefits of existing deferred tax assets. When the evaluation indicates that Entergy will not be able to realize the existing benefits, a valuation allowance is recorded to reduce deferred tax assets to the realizable amount.

Because it is more likely than not that the benefits from certain state net operating losses and other deferred tax assets will not be utilized, valuation allowances totaling $325 million as of December 31, 2021 and $329 million as of December 31, 2020 have been provided on the deferred tax assets related to federal and state jurisdictions in which Entergy does not currently expect to be able to utilize certain separate company tax return attributes, preventing realization of such deferred tax assets. As a result of incurring costs related to Hurricane Ida restoration, certain Utility operating companies are entitled to an accelerated tax deduction which generated a taxable loss in various taxing jurisdictions. This accelerated deduction has impaired the realizability of a limited term carryover tax attribute. Accordingly, the impairment contributed to the activity reflected for the valuation allowance disclosed above.
Significant components of accumulated deferred income taxes and taxes accrued for the Registrant Subsidiaries as of December 31, 2021 and 2020 are as follows:
2021Entergy ArkansasEntergy LouisianaEntergy MississippiEntergy New OrleansEntergy TexasSystem Energy
 (In Thousands)
Deferred tax liabilities:      
Plant basis differences - net($1,158,523)($3,429,473)($681,968)($192,660)($654,252)($433,874)
Regulatory assets(226,687)(530,274)(34,799)(30,694)(45,470)(61,205)
Nuclear decommissioning trusts/receivables(175,882)(186,382)— — — (153,610)
Pension, net regulatory asset(92,881)(93,681)(22,253)(11,429)(19,914)(18,033)
Deferred fuel(27,497)(13,686)(30,409)(1,600)(10,139)(49)
Accumulated storm damage provision— (193,967)— — (13,276)— 
Other(77,820)(138,299)(29,108)(33,071)(2,526)(5,622)
Total(1,759,290)(4,585,762)(798,537)(269,454)(745,577)(672,393)
Deferred tax assets:      
Regulatory liabilities310,256 634,184 59,418 36,057 55,022 224,036 
Nuclear decommissioning liabilities123,568 (909)(433)94 9,432 
Pension and other post-employment benefits(26,577)73,006 (7,793)(16,090)(18,793)(1,925)
Sale and leaseback— — — — — 102,474 
Accumulated deferred investment tax credit7,518 30,666 2,723 4,391 1,958 10,729 
Provision for allowances and contingencies24,829 21,768 10,236 5,559 7,730 — 
Power purchase agreements— — 1,140 — (1,202)— 
Unbilled/deferred revenues3,331 9,919 2,306 971 10,196 — 
Compensation3,347 5,288 2,181 1,036 1,618 447 
Net operating loss carryforwards275,054 1,228,547 166,008 105,549 81 — 
Capital losses and miscellaneous tax credits— 5,141 1,258 10,977 883 1,958 
Other19,397 5,968 2,891 7,788 863 
Total740,723 2,013,578 240,369 155,805 58,450 347,153 
Non-current accrued taxes (including unrecognized tax benefits)(397,634)138,330 (161,929)(251,735)(5,369)(57,691)
Accumulated deferred income taxes and taxes accrued($1,416,201)($2,433,854)($720,097)($365,384)($692,496)($382,931)
2020Entergy ArkansasEntergy LouisianaEntergy MississippiEntergy New OrleansEntergy TexasSystem Energy
 (In Thousands)
Deferred tax liabilities:      
Plant basis differences - net($1,117,948)($2,481,976)($623,796)($83,457)($620,669)($407,125)
Regulatory assets(188,284)(95,135)(22,381)(20,276)(47,684)(56,496)
Nuclear decommissioning trusts/receivables(156,123)(148,040)— — — (131,985)
Pension, net funding(93,486)(95,854)(24,922)(11,564)(19,481)(20,330)
Deferred fuel— (4,210)(1,706)(1,393)— (314)
Other(54,753)(76,735)(27,565)(26,334)(141)(12,521)
Total(1,610,594)(2,901,950)(700,370)(143,024)(687,975)(628,771)
Deferred tax assets:      
Regulatory liabilities273,774 218,278 56,022 31,248 47,991 163,534 
Nuclear decommissioning liabilities123,319 7,767 — (419)121 29,916 
Pension and other post-employment benefits(24,747)72,724 (6,763)(13,997)(17,132)(1,344)
Sale and leaseback— — — — — 102,477 
Accumulated deferred investment tax credit7,971 31,155 2,261 4,197 2,088 9,706 
Provision for allowances and contingencies22,179 7,071 16,799 24,529 (4,094)— 
Power purchase agreements9,662 3,381 1,140 (5,324)(30,932)— 
Unbilled/deferred revenues4,242 (23,382)2,989 877 5,909 — 
Compensation2,264 3,240 1,670 761 1,308 48 
Net operating loss carryforwards119,555 363,806 54,262 26,564 53,052 — 
Capital losses and miscellaneous tax credits— 9,309 — 12,317 — 7,014 
Other16,036 6,958 3,507 8,128 2,232 
Total554,255 700,307 131,887 88,881 60,543 311,353 
Non-current accrued taxes (including unrecognized tax benefits)(229,784)63,121 (78,191)(284,571)(11,990)(42,417)
Accumulated deferred income taxes and taxes accrued($1,286,123)($2,138,522)($646,674)($338,714)($639,422)($359,835)
The Registrant Subsidiaries’ estimated tax attributes carryovers and their expiration dates as of December 31, 2021 are as follows:

 Entergy ArkansasEntergy LouisianaEntergy MississippiEntergy New OrleansEntergy TexasSystem Energy
       
Federal net operating losses before 1/1/2018$— billion$1.7 billion$— billion$0.9 billion$— billion$— billion
Year(s) of expirationN/A2035-2037N/A2037N/AN/A
Federal net operating losses - 1/1/2018 forward$4.5 billion$4.5 billion$2.1 billion$0.7 billion$2.6 billion$— billion
Year(s) of expirationN/AN/AN/AN/AN/AN/A
       
State net operating losses$4.8 billion$7.2 billion$2.3 billion$1.7 billion$— million$— million
Year(s) of expiration2023-2026N/A2038-2041N/AN/AN/A
       
Misc. federal credits$4.7 million$12.3 million$1.8 million$15.3 million$3.1 million$1.5 million
Year(s) of expiration2038-20412035-20412038-20412037-20412036-20412036-2041
       
State credits$— million$— million$1.3 million$—million$2.9 million$9 million
Year(s) of expirationN/AN/A2022-2025N/A20272022-2025

As a result of the accounting for uncertain tax positions, the amount of the deferred tax assets reflected in the financial statements is less than the amount of the tax effect of the federal and state net operating loss carryovers and tax credit carryovers.

Unrecognized tax benefits

Accounting standards establish a “more-likely-than-not” recognition threshold that must be met before a tax benefit can be recognized in the financial statements.  If a tax deduction is taken on a tax return but does not meet the more-likely-than-not recognition threshold, an increase in income tax liability, above what is payable on the tax return, is required to be recorded.  A reconciliation of Entergy’s beginning and ending amount of unrecognized tax benefits is as follows:
 202120202019
 (In Thousands)
Gross balance at January 1$5,699,339 $7,383,154 $7,181,482 
Additions based on tax positions related to the current year101,623 669,207 731,276 
Additions for tax positions of prior years33,419 98,591 151,628 
Reductions for tax positions of prior years (74,413)(935,735)(681,232)
Settlements— (1,515,878)— 
Gross balance at December 315,759,968 5,699,339 7,383,154 
Offsets to gross unrecognized tax benefits:   
Loss and tax credit carryovers(4,987,799)(4,710,214)(5,831,587)
Cash paid to taxing authorities(60,000)(10,000)(10,000)
Unrecognized tax benefits net of unused tax attributes, refund claims and payments (a)$712,169 $979,125 $1,541,567 
(a)Potential tax liability above what is payable on tax returns

The balances of unrecognized tax benefits include $2,256 million, $2,208 million, and $2,421 million as of December 31, 2021, 2020, and 2019, respectively, which, if recognized, would lower the effective income tax rates.  Because of the effect of deferred tax accounting, the remaining balances of unrecognized tax benefits of $3,504 million, $3,491 million, and $4,962 million as of December 31, 2021, 2020, and 2019, respectively, if disallowed, would not affect the annual effective income tax rate but would accelerate the payment of cash to the taxing authority to an earlier period.

Entergy accrues interest expense, if any, related to unrecognized tax benefits in income tax expense.  Entergy’s December 31, 2021, 2020, and 2019 accrued balance for the possible payment of interest is approximately $52 million, $44 million, and $48 million, respectively. Interest (net-of-tax) of $8 million, ($4) million, and $4 million was recorded in 2021, 2020, and 2019, respectively.

A reconciliation of the Registrant Subsidiaries’ beginning and ending amount of unrecognized tax benefits for 2021, 2020, and 2019 is as follows:
2021Entergy ArkansasEntergy LouisianaEntergy MississippiEntergy New OrleansEntergy TexasSystem Energy
 (In Thousands)
Gross balance at January 1, 2021$1,364,635 $640,295 $549,717 $639,546 $521,932 $21,652 
Additions based on tax positions related to the current year30,419 13,437 684 1,050 32,616 1,753 
Additions for tax positions of prior years15,013 9,304 1,504 2,315 1,897 
Reductions for tax positions of prior years(1,573)(58,408)(2,336)(1,105)(4,568)(1,946)
Gross balance at December 31, 20211,408,494 604,628 549,569 639,497 552,295 23,356 
Offsets to gross unrecognized tax benefits:      
Loss and tax credit carryovers(992,643)(604,628)(388,728)(484,899)(540,694)(8,576)
Unrecognized tax benefits net of unused tax attributes and payments$415,851 $— $160,841 $154,598 $11,601 $14,780 

2020Entergy ArkansasEntergy LouisianaEntergy MississippiEntergy New OrleansEntergy TexasSystem Energy
 (In Thousands)
Gross balance at January 1, 2020$1,341,242 $2,381,653 $566,287 $716,773 $21,406 $473,331 
Additions based on tax positions related to the current year (a)9,403 35,681 5,619 2,430 504,362 4,013 
Additions for tax positions of prior years13,400 10,508 1,156 294 799 4,606 
Reductions for tax positions of prior years(11,346)(679,601)(24,173)(80,267)(5,559)(41,466)
Settlements11,936 (1,107,946)828 316 924 (418,832)
Gross balance at December 31, 20201,364,635 640,295 549,717 639,546 521,932 21,652 
Offsets to gross unrecognized tax benefits:      
Loss and tax credit carryovers(1,112,628)(640,295)(465,679)(451,922)(507,720)(7,413)
Unrecognized tax benefits net of unused tax attributes and payments$252,007 $— $84,038 $187,624 $14,212 $14,239 
2019Entergy ArkansasEntergy LouisianaEntergy MississippiEntergy New OrleansEntergy TexasSystem Energy
 (In Thousands)
Gross balance at January 1, 2019$1,298,662 $2,400,171 $508,765 $686,687 $17,802 $467,487 
Additions based on tax positions related to the current year84,335 28,705 68,594 40,676 2,312 5,496 
Additions for tax positions of prior years20,399 25,090 1,651 489 1,299 2,186 
Reductions for tax positions of prior years(62,154)(72,313)(12,723)(11,079)(7)(1,838)
Gross balance at December 31, 20191,341,242 2,381,653 566,287 716,773 21,406 473,331 
Offsets to gross unrecognized tax benefits:      
Loss and tax credit carryovers(1,134,187)(1,573,257)(506,976)(445,430)(3,944)(8,392)
Unrecognized tax benefits net of unused tax attributes and payments$207,055 $808,396 $59,311 $271,343 $17,462 $464,939 

(a)The primary additions for Entergy Texas in 2020 are related to the mark-to-market treatment discussed in “Other Tax Matters - Tax Accounting Methods” below.

The Registrant Subsidiaries’ balances of unrecognized tax benefits included amounts which, if recognized, would have reduced income tax expense as follows:
December 31,
 202120202019
 (In Millions)
Entergy Arkansas$262.1 $259.3 $203.3 
Entergy Louisiana$66.3 $63.8 $556.3 
Entergy Mississippi$51.7 $50.7 $1.9 
Entergy New Orleans$228.6 $203.5 $242.7 
Entergy Texas$2.6 $6.1 $5.7 
System Energy$1.7 $0.5 $— 

Accrued balances for the possible payment of interest related to unrecognized tax benefits are as follows:
December 31,
 202120202019
 (In Millions)
Entergy Arkansas$2.7 $2.3 $3.1 
Entergy Louisiana$3.7 $3.4 $14.2 
Entergy Mississippi$2.4 $1.9 $1.7 
Entergy New Orleans$5.2 $3.9 $4.7 
Entergy Texas$1.1 $0.9 $1.1 
System Energy$12.1 $11.9 $14.5 
The Registrant Subsidiaries record interest and penalties related to unrecognized tax benefits in income tax expense.  No penalties were recorded in 2021, 2020, and 2019. Interest (net-of-tax) was recorded as follows:
202120202019
(In Millions)
Entergy Arkansas$0.4 ($0.8)$1.4 
Entergy Louisiana$0.3 ($10.8)($3.7)
Entergy Mississippi$0.5 $0.2 $0.5 
Entergy New Orleans$1.3 ($0.8)$2.0 
Entergy Texas$0.2 ($0.2)$0.2 
System Energy$0.2 ($2.6)$1.3 

Income Tax Audits

Entergy and its subsidiaries file U.S. federal and various state income tax returns.  IRS examinations are complete for years before 2016. All state taxing authorities’ examinations are complete for years before 2014. Entergy regularly defends its positions and works with the IRS to resolve audits.  The resolution of audit issues could result in significant changes to the amounts of unrecognized tax benefits in the next twelve months.

2014-2015 IRS Audit

The IRS completed its examination of the 2014 and 2015 tax years and issued its 2014-2015 RAR in November 2020. Entergy agreed to all proposed adjustments contained in the RAR. Entergy and the Registrant Subsidiaries recorded the effects of the adjustments associated with the audit in 2020.

In October 2015 two of Entergy’s Louisiana utilities, Entergy Gulf States Louisiana and Entergy Louisiana, combined their businesses into a legal entity which is identified as Entergy Louisiana herein. The structure of the business combination required Entergy to recognize a gain for income tax purposes which resulted in an increase in the tax basis of the assets for Entergy Louisiana. This resulted in recognition in 2015 of a $334 million permanent difference and income tax benefit, net of the uncertain tax position recorded on the transaction.

Primarily related to resolution of the business combination issues, completion of the 2014-2015 IRS audit in 2020 resulted in a $230 million reduction to deferred income tax expense for Entergy. This reduction to deferred income tax expense includes: Entergy Louisiana reversing its provision for uncertain tax position with respect to the business combination, which resulted in a reduction to deferred income tax expense of $383 million; Entergy Corporation recording an increase to deferred tax expense of $61 million and Entergy Wholesale Commodities recording an increase to deferred tax expense of $105 million from the re-measurement of deferred tax assets associated with the resolved uncertain tax position; and miscellaneous other individually insignificant benefits totaling $13 million.

The completion of the 2014-2015 tax audit also resulted in a $31 million reduction to income tax expense associated with Entergy Louisiana’s method of accounting related to the adoption of tangible property regulations. As a result of the settlement of the tangible property regulation tax position, Entergy Louisiana was required to record a $33 million ($24 million net-of-tax) regulatory charge and a corresponding regulatory liability to reflect its obligation to customers pursuant to a prior regulatory settlement.

Finally, upon completion of the 2014-2015 tax audit, Entergy New Orleans recorded a reduction to income tax expense of $8 million associated with claims for mark-to-market deductions.

In the first quarter 2020, Entergy and the IRS agreed on the treatment of funds received by Entergy Louisiana in conjunction with the Act 55 financing of Hurricane Isaac storm costs, which resulted in a net reduction
of income tax expense of approximately $32 million. As a result of the settlement, the position was partially sustained, and Entergy Louisiana recorded a reduction of income tax expense of approximately $58 million primarily due to the reversal of a provision for uncertain tax positions in excess of the agreed-upon settlement. As a result of the IRS settlement, Entergy Louisiana recorded a $29 million ($21 million net-of-tax) regulatory charge and a corresponding regulatory liability to reflect its obligation to customers pursuant to the LPSC Hurricane Isaac Act 55 financing order.

Additional effects of the completion of the 2014-2015 IRS tax audit are discussed below within Tax Accounting Methods.

Other Tax Matters

Tax Cuts and Jobs Act (TCJA)

The most significant effect of the TCJA for Entergy and the Registrant Subsidiaries was the change in the federal corporate income tax rate from 35% to 21%, effective January 1, 2018.

TCJA also limited the deduction for net business interest expense to 30 percent of adjusted taxable income, which is similar to earnings before interest, taxes, depreciation, and amortization. The limitation does not apply to interest expense that is properly allocable to a trade or business classified as a regulated public utility. This was further modified by a temporary provision of the CARES Act resulting in an increase of the adjusted taxable income limitation from 30% to 50% for tax years that begin in 2019 or 2020.

The IRS issued final regulations which are effective for Entergy beginning with the 2021 tax year. The regulations provide that if 90% of a tax group’s consolidated assets consist of regulated utility property, the entire consolidated tax group will be treated as a regulated public utility and all of the consolidated group’s interest expense will be currently tax deductible. Entergy expects that this provision will continue to apply to Entergy’s business operations making the application of this limitation to Entergy less likely. The provision has not resulted in Entergy having to report any significant business interest expense limitations on its tax returns.

With respect to the federal corporate income tax rate change from 35% to 21% in 2017, Entergy and the Registrant Subsidiaries recorded a regulatory liability associated with the decrease in the net accumulated deferred income tax liability, which is often referred to as “excess ADIT,” a significant portion of which has been paid to customers in 2019, 2020 and 2021 in the form of lower rates. Entergy’s December 31, 2021 and December 31, 2020 balance sheets reflect a regulatory liability of $1.3 billion and $1.6 billion, respectively, as a result of the re-measurement of deferred tax assets and liabilities from the income tax rate change, amortization of excess ADIT, and payments to customers during 2019, 2020 and 2021. Entergy’s regulatory liability for income taxes includes a gross-up at the applicable tax rate because of the effect that excess ADIT has on the ratemaking formula. The regulatory liability for income taxes includes the effect of a) the reduction of the net deferred tax liability resulting in excess ADIT, and b) the tax gross-up of excess ADIT. The Registrant Subsidiaries’ December 31, 2021 and December 31, 2020 balance sheets reflect net regulatory liabilities for income taxes as follows:
20212020
(In Millions)
Entergy Arkansas$432 $467 
Entergy Louisiana$338 $479 
Entergy Mississippi$212 $224 
Entergy New Orleans$42 $59 
Entergy Texas$171 $205 
System Energy$113 $152 
Excess ADIT is generally classified into two categories: 1) the portion that is subject to the normalization requirements of the TCJA, i.e., “protected”, and 2) the portion that is not subject to such normalization provisions, referred to as “unprotected”. The TCJA provides that the normalization method of accounting for income taxes is required for excess ADIT associated with public utility property. The TCJA provides for the use of the average rate assumption method (ARAM) for the determination of the timing of the return of excess ADIT associated with such property. Under ARAM, the excess ADIT is reduced over the remaining life of the asset. Remaining asset lives vary for each Registrant Subsidiary, but the average life of public utility property is typically 30 years or longer. Entergy will amortize the protected portion of the excess ADIT in conformity with the normalization requirements. The Registrant Subsidiaries’ net regulatory liability for income taxes as of December 31, 2021 and December 31, 2020, includes protected excess ADIT as follows:
20212020
(In Millions)
Entergy Arkansas$463 $490 
Entergy Louisiana$669 $721 
Entergy Mississippi$237 $248 
Entergy New Orleans$56 $61 
Entergy Texas$208 $215 
System Energy$148 $173 

Payment of the unprotected excess accumulated deferred income taxes results in a reduction in the regulatory liability for income taxes and a corresponding reduction in income tax expense. This has a significant effect on the effective tax rate for the period as compared to the statutory tax rate. The Registrant Subsidiaries’ net regulatory liability for income taxes as of December 31, 2021 and December 31, 2020, includes unprotected excess ADIT as follows:
20212020
(In Millions)
Entergy Arkansas$12 $11 
Entergy Louisiana$148 $223 
Entergy New Orleans$— $3 
Entergy Texas$26 $54 
System Energy$— $16 

The return of unprotected excess accumulated deferred income taxes reduced Entergy’s and the Registrant Subsidiaries’ regulatory liability for income taxes as follows for 2021 and 2020:
20212020
(In Millions)
Entergy$88 $74 
Entergy Arkansas$8 $8 
Entergy Louisiana$33 $31 
Entergy New Orleans$1 $6 
Entergy Texas$28 $29 
System Energy$18 $— 

In addition to the protected and unprotected excess ADIT amounts, the net regulatory liability for income taxes includes other regulatory assets and liabilities for income taxes associated with AFUDC, which is described in Note 1 to the financial statements.
Included in the effect of the computation of the changes in deferred tax assets and liabilities is the recognition threshold and measurement of uncertain tax positions resulting in unrecognized tax benefits. The final economic outcome of such unrecognized tax benefits is generally the result of a negotiated settlement with the IRS that often differs from the amount that is recorded as realizable under GAAP. The intrinsic uncertainty with respect to all such tax positions means that the difference between current estimates of such amounts likely to be realized and actual amounts realized upon settlement may have an effect on income tax expense and the regulatory liability for income taxes in future periods.

Entergy anticipates that the effect of TCJA may continue to have ramifications that require adjustments in the future as certain events occur. These events include: 1) IRS audit adjustments to or amendments of federal and state income tax returns that include modifications to the computation of taxable income resulting from TCJA; and 2) additional guidance, interpretations, or rulings by the U.S. Department of the Treasury or the IRS. The potential exists for these types of events to result in future tax expense adjustments because of the difference in the federal corporate income tax rate between past and future periods and the effect of the tax rate change on ratemaking. In turn, these events also could potentially affect the regulatory liability for income taxes.

Coronavirus Aid, Relief, and Economic Security Act

In response to the economic impacts of the COVID-19 pandemic, President Trump signed the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) into law on March 27, 2020. The CARES Act provisions that result in the most significant opportunities for tax relief to Entergy and the Registrant Subsidiaries are (i) permitting a five-year carryback of 2018-2020 NOLs, (ii) removing the 80 percent limitation on NOLs carried to tax years beginning before 2021, (iii) increasing the limitation on interest expense deductibility for 2019 and 2020, (iv) accelerating available refunds for minimum tax credit carryforwards, modifying limitations on charitable contributions during 2020, and (v) delaying the payment of employer payroll taxes. Entergy deferred approximately $64 million of 2020 payroll tax payments, payable in equal installments over two years. The initial installment of $32 million was paid in December 2021. The second installment will be paid in December 2022.

Entergy Wholesale Commodities Restructuring

In the fourth quarter 2019, two separate events occurred resulting in a reduction of tax expense of $174 million. In November 2019 an Entergy Wholesale Commodities subsidiary recognized a reduction in income tax expense of $18 million in connection with the accounting method on power contracts associated with the Palisades nuclear power station. Additionally, Entergy’s ownership of Indian Point 2 and Indian Point 3 was restructured. The restructuring required Entergy to recognize Indian Point 2 and Indian Point 3 nuclear decommissioning liabilities for income tax purposes resulting in a tax accounting permanent difference that reduced income tax expense, net of unrecognized tax benefits, by $156 million. The accrual of the nuclear decommissioning liabilities also required Entergy to recognize a gain for income tax purposes, a portion of which resulted in an increase in the tax basis of the assets. Recognition of the gain and the increase in the tax basis of the assets represents a tax accounting temporary difference.

Immediately prior to the restructuring, through its ownership of Indian Point 2 and Indian Point 3, Entergy donated property to Stony Brook University and recognized an associated tax deduction resulting in a decrease to tax expense of $19 million.

In the fourth quarter 2020, Entergy’s ownership of Palisades was restructured. The restructuring required Entergy to recognize Palisades’ nuclear decommissioning liability for income tax purposes resulting in a tax accounting permanent difference that reduced income tax expense, net of unrecognized tax benefits, by $9.2 million. The accrual of the nuclear decommissioning liability also required Entergy to recognize a gain for income tax purposes, a portion of which resulted in an increase in the tax basis of the assets. Recognition of the gain and the increase in the tax basis of the assets represents a tax accounting temporary difference.
Tax Accounting Methods

In the fourth quarter 2015, System Energy and Entergy Louisiana adopted a new method of accounting for income tax return purposes in which their nuclear decommissioning costs will be treated as production costs of electricity includable in cost of goods sold. The new method resulted in a reduction of taxable income of $1.2 billion for System Energy and $2.2 billion for Energy Louisiana.

In conjunction with the 2014-2015 IRS audit discussed above, the IRS issued proposed adjustments concerning the nuclear decommissioning tax position allowing System Energy to include $102 million of its decommissioning liability in cost of goods sold, and Entergy Louisiana to include $221 million of its decommissioning liability in cost of goods sold. Entergy, System Energy, and Entergy Louisiana agreed to the proposed adjustments included in the RAR.

As a result of System Energy being allowed to include part of its decommissioning liability in cost of goods sold, System Energy and Entergy recorded a deferred tax liability of $26 million. System Energy also recorded federal and state taxes payable of $402 million. However, on a consolidated basis, Entergy utilized tax loss carryovers to offset the federal taxable income adjustment and did not record federal taxes payable as a result of the outcome of this uncertain tax position.

As a result of Entergy Louisiana being allowed to include part of its decommissioning liability in cost of goods sold, Entergy Louisiana and Entergy recorded a deferred tax liability of $60 million. Both Entergy Louisiana and Entergy utilized tax loss carryovers to offset the taxable income adjustment and accordingly did not record taxes payable as a result of the outcome of this uncertain tax position.

The partial disallowance of this uncertain tax position to include the decommissioning liability in cost of goods sold resulted in a $1.5 billion decrease in the balance of unrecognized tax benefits related to federal and state taxes for Entergy. Additionally, both System Energy and Entergy Louisiana recorded a reduction to their balances of unrecognized tax benefits for federal and state taxes of $461 million and $1.1 billion, respectively.

Entergy Arkansas adopted the same method of accounting for its nuclear decommissioning costs which resulted in a $1.8 billion reduction in taxable income on its 2018 tax return.

In 2016, Entergy Louisiana elected mark-to-market income tax treatment for various wholesale electric power purchase and sale agreements, including Entergy Louisiana’s contract to purchase electricity from the Vidalia hydroelectric facility and from System Energy under the Unit Power Sales Agreement. The election resulted in a $2.2 billion deductible temporary difference. In 2017, Entergy New Orleans also elected mark-to-market income tax treatment for wholesale electric contracts which resulted in a $1.1 billion deductible temporary difference. In 2018, Entergy Arkansas and Entergy Mississippi accrued deductible temporary differences related to mark-to-market tax accounting for wholesale electric contracts of $2.1 billion and $1.9 billion, respectively. Additionally, in 2020, Entergy Texas elected mark-to-market income tax treatment for wholesale electric power purchase and sale agreements which resulted in a $2.5 billion deductible temporary difference.

Arkansas and Louisiana Corporate Income Tax Rate Changes

In April 2019 and December 2021 the State of Arkansas enacted corporate income tax law changes that phased in rate reductions from the former rate of 6.5% to 6.2% in 2021, 5.9% in 2022, and 5.7% in 2023.    As a result of the 2019 rate reduction, Entergy Arkansas computed a regulatory liability for income taxes as of December 31, 2020 of approximately $21 million, which includes a tax gross-up related to the treatment of income taxes in the retail and wholesale ratemaking formulas and has been included in the appropriate rate mechanisms. Entergy Arkansas recorded an incremental regulatory liability of $11 million associated with the rate reduction enacted in December 2021. The Arkansas tax law enactment also phases in an increase to the net operating loss carryover period from five to ten years.
Pursuant to legislation enacted in 2021 and approved by Louisiana citizens by amendment to the state constitution, beginning January 1, 2022, federal income taxes paid will no longer be deductible for state income tax purposes, and the top Louisiana corporate income tax rate will be reduced from 8% to 7.5%. As a result of this change in Louisiana tax law, the Louisiana applicable tax rate increased by 0.85%. Accordingly, deferred tax assets and liabilities were adjusted to reflect the new applicable federal and state rates. Legislation enacted in 2021 also provides that Louisiana net operating losses generally have an indefinite carryover period.

Entergy recorded a net increase to its deferred tax asset of $27 million. Entergy Louisiana and Entergy New Orleans recorded net increases to their deferred tax liabilities before consideration of the tax gross-up of $77 million and $8 million, respectively, which were offset by regulatory assets for income taxes. Therefore, these increases had no effect on tax expense. However, the increase of deferred tax assets associated with certain assets reduced tax expense for Entergy Louisiana and Entergy New Orleans by $6 million and $2 million, respectively.

Consolidated Income Tax Return of Entergy Corporation

In September 2019, Entergy Utility Holding Company, LLC and its regulated, wholly-owned subsidiaries including Entergy Arkansas, Entergy Louisiana, Entergy Mississippi, and Entergy New Orleans, became eligible to and joined the Entergy Corporation consolidated federal income tax group.  As a result of these four Utility operating companies re-joining the Entergy Corporation consolidated tax return group, Entergy was able to recognize a $41 million deferred tax asset associated with a previously unrecognized net operating loss carryover.

In September 2019, Entergy Texas issued $35 million of 5.375% Series A preferred stock with a liquidation value of $25 per share resulting in the disaffiliation and de-consolidation of Entergy Texas from the consolidated federal income tax return of Entergy Corporation.  These changes will not affect the accrual or allocation of income taxes for the Registrant Subsidiaries. See Note 6 to the financial statements for discussion of the preferred stock issuance.

Vermont Yankee

The Vermont Yankee transaction resulted in Entergy generating a net deferred tax asset in January 2019.  The deferred tax asset could not be fully realized by Entergy in the first quarter 2019; accordingly, Entergy accrued a net tax expense of $29 million on the disposition of Vermont Yankee. See Note 14 to the financial statements for discussion of the Vermont Yankee transaction.

Stock Compensation

In accordance with stock compensation accounting rules, Entergy and the Registrant Subsidiaries recognized excess tax deductions as a reduction of income tax expense in the first quarter 2020. Due to the vesting and exercise of certain Entergy stock-based awards, Entergy recorded a permanent tax reduction of approximately $24.7 million, including $4.8 million for Entergy Arkansas, $8.6 million for Entergy Louisiana, $2.7 million for Entergy Mississippi, $1.5 million for Entergy New Orleans, $2.7 million for Entergy Texas, and $1.3 million for System Energy.
Entergy Arkansas [Member]  
Income Taxes INCOME TAXES (Entergy Corporation, Entergy Arkansas, Entergy Louisiana, Entergy Mississippi, Entergy New Orleans, Entergy Texas, and System Energy)
Income taxes for 2021, 2020, and 2019 for Entergy Corporation and Subsidiaries consist of the following:
 202120202019
 (In Thousands)
Current:   
Federal($5,003)$5,807 ($14,416)
State(8,995)57,939 6,535 
Total(13,998)63,746 (7,881)
Deferred and non-current - net205,891 (190,635)(155,956)
Investment tax credit adjustments - net(519)5,383 (5,988)
Income taxes$191,374 ($121,506)($169,825)

Income taxes for 2021, 2020, and 2019 for Entergy’s Registrant Subsidiaries consist of the following:
2021Entergy ArkansasEntergy LouisianaEntergy MississippiEntergy New OrleansEntergy TexasSystem Energy
(In Thousands)
Current:      
Federal($20,285)($24,053)($5,868)($6,724)($189)$29,416 
State529 2,459 (11,506)(413)1,261 (10,258)
Total(19,756)(21,594)(17,374)(7,137)1,072 19,158 
Deferred and non-current - net96,180 146,786 60,861 12,870 25,087 (25,229)
Investment tax credit adjustments - net(1,229)(4,783)1,836 203 (633)4,094 
Income taxes$75,195 $120,409 $45,323 $5,936 $25,526 ($1,977)

2020Entergy ArkansasEntergy LouisianaEntergy MississippiEntergy New OrleansEntergy TexasSystem Energy
 (In Thousands)
Current:      
Federal($44,627)$62,728 ($14,580)$293 ($5,603)$372,206 
State(2,563)4,457 (1,316)(303)2,658 55,551 
Total(47,190)67,185 (15,896)(10)(2,945)427,757 
Deferred and non-current - net96,195 (444,647)43,640 (18,153)6,619 (405,928)
Investment tax credit adjustments - net(1,228)(4,862)(554)13,956 (632)(1,286)
Income taxes$47,777 ($382,324)$27,190 ($4,207)$3,042 $20,543 
2019Entergy ArkansasEntergy LouisianaEntergy MississippiEntergy New OrleansEntergy TexasSystem Energy
 (In Thousands)
Current:      
Federal($14,549)($20,173)($8,939)($5,822)$16,035 $16,256 
State(714)(735)5,823 1,856 663 (2,831)
Total(15,263)(20,908)(3,116)(3,966)16,698 13,425 
Deferred and non-current - net(30,278)147,453 34,579 4,248 (69,963)422 
Investment tax credit adjustments - net(1,228)(4,922)(597)(96)(631)1,502 
Income taxes($46,769)$121,623 $30,866 $186 ($53,896)$15,349 

Total income taxes for Entergy Corporation and Subsidiaries differ from the amounts computed by applying the statutory income tax rate to income before income taxes.  The reasons for the differences for the years 2021, 2020, and 2019 are:
 202120202019
 (In Thousands)
Net income attributable to Entergy Corporation$1,118,492 $1,388,334 $1,241,226 
Preferred dividend requirements of subsidiaries227 18,319 17,018 
Consolidated net income1,118,719 1,406,653 1,258,244 
Income taxes191,374 (121,506)(169,825)
Income before income taxes$1,310,093 $1,285,147 $1,088,419 
Computed at statutory rate (21%)$275,120 $269,881 $228,568 
Increases (reductions) in tax resulting from:   
State income taxes net of federal income tax effect79,273 60,087 61,791 
Regulatory differences - utility plant items(57,556)(53,229)(45,336)
Equity component of AFUDC(14,799)(25,080)(30,444)
Amortization of investment tax credits(7,695)(8,386)(8,093)
Flow-through / permanent differences(5,585)11,099 (2,059)
Amortization of excess ADIT (a)(66,478)(59,629)(205,614)
Arkansas and Louisiana Rate Changes (b)(27,108)— — 
IRS audit adjustment (d)— (301,041)— 
Entergy Wholesale Commodities restructuring (c)— (9,223)(173,725)
Stock compensation (e)— (25,591)— 
Charitable contribution (c)— — (19,101)
Net operating loss recognition— — (41,427)
Provision for uncertain tax positions16,533 15,208 7,332 
Valuation allowance(2,600)— 59,345 
Other - net2,269 4,398 (1,062)
Total income taxes as reported$191,374 ($121,506)($169,825)
Effective Income Tax Rate14.6 %(9.5 %)(15.6 %)

(a)See “Other Tax Matters - Tax Cuts and Jobs Act” below for discussion of the amortization of excess accumulated deferred income taxes (ADIT) in 2019, 2020, and 2021 and the tax legislation enactment in 2017.
(b)See “Arkansas and Louisiana Corporate Income Tax Rate Changes” below for details.
(c)See Other Tax Matters - Entergy Wholesale Commodities Restructuring” below for discussion of the Entergy Wholesale Commodities restructuring in 2019, the ownership of Palisades restructuring in 2020, and the charitable contribution in 2019.
(d)See “Income Tax Audits - 2014-2015 IRS Audit” below for discussion of the resolution of the audit in 2020.
(e)See “Other Tax Matters - Stock Compensation” below for discussion of excess tax deductions.

Total income taxes for the Registrant Subsidiaries differ from the amounts computed by applying the statutory income tax rate to income before taxes.  The reasons for the differences for the years 2021, 2020, and 2019 are:
2021Entergy ArkansasEntergy LouisianaEntergy MississippiEntergy New OrleansEntergy TexasSystem Energy
 (In Thousands)
Net income$298,484 $653,984 $166,834 $31,798 $228,824 $106,814 
Income taxes75,195 120,409 45,323 5,936 25,526 (1,977)
Pretax income$373,679 $774,393 $212,157 $37,734 $254,350 $104,837 
Computed at statutory rate (21%)$78,473 $162,623 $44,553 $7,924 $53,413 $22,016 
Increases (reductions) in tax resulting from:     
State income taxes net of federal income tax effect19,633 41,030 9,305 2,579 1,553 5,385 
Regulatory differences - utility plant items(16,078)(14,123)(8,133)(4,332)(2,115)(12,776)
Equity component of AFUDC(3,207)(6,016)(1,701)(498)(2,077)(1,300)
Amortization of investment tax credits(1,201)(4,729)64 (56)(617)(1,155)
Flow-through / permanent differences(814)(2,655)124 1,559 (475)(1,235)
Amortization of excess ADIT (a)(5,845)(24,323)— (1,028)(21,929)(13,354)
Arkansas and Louisiana Rate Changes (b)398 (6,126)395 (1,569)216 115 
Non-taxable dividend income— (26,801)— — — — 
Provision for uncertain tax positions353 300 465 1,200 (2,716)200 
Valuation Allowance2,766 — — — — — 
Other - net717 1,229 251 157 273 127 
Total income taxes as reported$75,195 $120,409 $45,323 $5,936 $25,526 ($1,977)
Effective Income Tax Rate20.1 %15.5 %21.4 %15.7 %10.0 %(1.9 %)
2020Entergy ArkansasEntergy LouisianaEntergy MississippiEntergy New OrleansEntergy TexasSystem Energy
 (In Thousands)
Net income$245,232 $1,082,352 $140,583 $49,338 $215,073 $99,131 
Income taxes47,777 (382,324)27,190 (4,207)3,042 20,543 
Pretax income$293,009 $700,028 $167,773 $45,131 $218,115 $119,674 
Computed at statutory rate (21%)$61,532 $147,006 $35,232 $9,478 $45,804 $25,132 
Increases (reductions) in tax resulting from:
State income taxes net of federal income tax effect16,256 38,182 6,917 2,606 1,460 5,524 
Regulatory differences - utility plant items(8,034)(23,819)(7,441)(3,442)(7,673)(2,821)
Equity component of AFUDC(3,154)(8,012)(1,412)(1,331)(9,255)(1,916)
Amortization of investment tax credits(1,201)(4,811)(540)(61)(617)(1,155)
Flow-through / permanent differences(2,219)1,404 (102)498 766 (421)
Amortization of excess ADIT (a)(6,011)(26,293)18 (4,564)(22,780)— 
Stock compensation (d)(4,952)(9,004)(2,763)(1,526)(2,842)(1,300)
IRS audit adjustment (c)(6,351)(471,702)(3,768)(6,819)(2,091)(2,925)
Non-taxable dividend income— (26,795)— — — — 
Provision for uncertain tax positions1,200 300 800 800 — 300 
Other - net711 1,220 249 154 270 125 
Total income taxes as reported$47,777 ($382,324)$27,190 ($4,207)$3,042 $20,543 
Effective Income Tax Rate16.3 %(54.6 %)16.2 %(9.3 %)1.4 %17.2 %

2019Entergy ArkansasEntergy LouisianaEntergy MississippiEntergy New OrleansEntergy TexasSystem Energy
 (In Thousands)
Net income$262,964 $691,537 $119,925 $52,629 $159,397 $99,120 
Income taxes(46,769)121,623 30,866 186 (53,896)15,349 
Pretax income$216,195 $813,160 $150,791 $52,815 $105,501 $114,469 
Computed at statutory rate (21%)$45,401 $170,764 $31,666 $11,091 $22,155 $24,039 
Increases (reductions) in tax resulting from:      
State income taxes net of federal income tax effect15,954 42,854 5,563 3,443 360 5,134 
Regulatory differences - utility plant items(10,627)(19,421)(5,556)(1,532)(1,987)(6,213)
Equity component of AFUDC(3,255)(15,545)(1,755)(2,088)(5,973)(1,829)
Amortization of investment tax credits(1,201)(4,871)(160)(88)(617)(1,155)
Flow-through / permanent differences696 439 160 (741)560 (500)
Amortization of excess ADIT (a)(90,921)(28,531)203 (11,724)(69,091)(5,550)
Non-taxable dividend income— (26,795)— — — — 
Provision for uncertain tax positions(3,517)1,519 500 1,672 430 1,300 
Other - net701 1,210 245 153 267 123 
Total income taxes as reported($46,769)$121,623 $30,866 $186 ($53,896)$15,349 
Effective Income Tax Rate(21.6 %)15.0 %20.5 %0.4 %(51.1 %)13.4 %
(a)See “Other Tax Matters - Tax Cuts and Jobs Act” below for discussion of the amortization of excess accumulated deferred income taxes (ADIT) in 2019, 2020 and 2021 and the tax legislation enactment in 2017.
(b)See “Arkansas and Louisiana Corporate Income Tax Rate Changes” below for details.
(c)See “Income Tax Audits - 2014-2015 IRS Audit” below for discussion of the resolution of the audit in 2020.
(d)See “Other Tax Matters - Stock Compensation” below for discussion of excess tax deductions.


Significant components of accumulated deferred income taxes and taxes accrued for Entergy Corporation and Subsidiaries as of December 31, 2021 and 2020 are as follows:
 
 20212020
 (In Thousands)
Deferred tax liabilities:  
Plant basis differences - net($6,136,563)($4,795,422)
Regulatory assets(930,244)(429,996)
Nuclear decommissioning trusts/receivables(656,185)(1,188,235)
Pension, net regulatory asset(322,788)(327,445)
Combined unitary state taxes(7,255)(7,723)
Unbilled/deferred revenues— (9,152)
Accumulated storm damage provision(207,243)— 
Deferred fuel(85,310)(7,667)
Other(341,450)(549,355)
Total(8,687,038)(7,314,995)
Deferred tax assets:  
Nuclear decommissioning liabilities278,136 968,464 
Regulatory liabilities1,318,381 791,927 
Pension and other post-employment benefits208,128 278,486 
Sale and leaseback102,474 102,477 
Compensation79,798 89,279 
Accumulated deferred investment tax credit57,986 57,379 
Provision for allowances and contingencies82,286 71,598 
Power purchase agreements55,259 352,019 
Unbilled/deferred revenues26,683 — 
Net operating loss carryforwards2,868,424 1,580,109 
Capital losses and miscellaneous tax credits11,111 21,291 
Valuation allowance(325,239)(328,581)
Other200,032 230,291 
Total4,963,459 4,214,739 
Non-current accrued taxes (including unrecognized tax benefits)(929,032)(1,185,227)
Accumulated deferred income taxes and taxes accrued($4,652,611)($4,285,483)
Entergy’s estimated tax attributes carryovers and their expiration dates as of December 31, 2021 are as follows:
Carryover DescriptionCarryover AmountYear(s) of expiration
   
Federal net operating losses before 1/1/2018$6.2 billion2023-2027
Federal net operating losses - 1/1/2018 forward$21.1 billionN/A
State net operating losses$7.4 billion2022-2041
State net operating losses with no expiration$16.7 billionN/A
Federal and state charitable contributions$460.8 million2022-2026
Miscellaneous federal and state credits$73.1 million2022-2041

As a result of the accounting for uncertain tax positions, the amount of the deferred tax assets reflected in the financial statements is less than the amount of the tax effect of the federal and state net operating loss carryovers, tax credit carryovers, and other tax attributes reflected on income tax returns. Entergy evaluates the available positive and negative evidence to estimate whether sufficient future taxable income of the appropriate character will be generated to realize the benefits of existing deferred tax assets. When the evaluation indicates that Entergy will not be able to realize the existing benefits, a valuation allowance is recorded to reduce deferred tax assets to the realizable amount.

Because it is more likely than not that the benefits from certain state net operating losses and other deferred tax assets will not be utilized, valuation allowances totaling $325 million as of December 31, 2021 and $329 million as of December 31, 2020 have been provided on the deferred tax assets related to federal and state jurisdictions in which Entergy does not currently expect to be able to utilize certain separate company tax return attributes, preventing realization of such deferred tax assets. As a result of incurring costs related to Hurricane Ida restoration, certain Utility operating companies are entitled to an accelerated tax deduction which generated a taxable loss in various taxing jurisdictions. This accelerated deduction has impaired the realizability of a limited term carryover tax attribute. Accordingly, the impairment contributed to the activity reflected for the valuation allowance disclosed above.
Significant components of accumulated deferred income taxes and taxes accrued for the Registrant Subsidiaries as of December 31, 2021 and 2020 are as follows:
2021Entergy ArkansasEntergy LouisianaEntergy MississippiEntergy New OrleansEntergy TexasSystem Energy
 (In Thousands)
Deferred tax liabilities:      
Plant basis differences - net($1,158,523)($3,429,473)($681,968)($192,660)($654,252)($433,874)
Regulatory assets(226,687)(530,274)(34,799)(30,694)(45,470)(61,205)
Nuclear decommissioning trusts/receivables(175,882)(186,382)— — — (153,610)
Pension, net regulatory asset(92,881)(93,681)(22,253)(11,429)(19,914)(18,033)
Deferred fuel(27,497)(13,686)(30,409)(1,600)(10,139)(49)
Accumulated storm damage provision— (193,967)— — (13,276)— 
Other(77,820)(138,299)(29,108)(33,071)(2,526)(5,622)
Total(1,759,290)(4,585,762)(798,537)(269,454)(745,577)(672,393)
Deferred tax assets:      
Regulatory liabilities310,256 634,184 59,418 36,057 55,022 224,036 
Nuclear decommissioning liabilities123,568 (909)(433)94 9,432 
Pension and other post-employment benefits(26,577)73,006 (7,793)(16,090)(18,793)(1,925)
Sale and leaseback— — — — — 102,474 
Accumulated deferred investment tax credit7,518 30,666 2,723 4,391 1,958 10,729 
Provision for allowances and contingencies24,829 21,768 10,236 5,559 7,730 — 
Power purchase agreements— — 1,140 — (1,202)— 
Unbilled/deferred revenues3,331 9,919 2,306 971 10,196 — 
Compensation3,347 5,288 2,181 1,036 1,618 447 
Net operating loss carryforwards275,054 1,228,547 166,008 105,549 81 — 
Capital losses and miscellaneous tax credits— 5,141 1,258 10,977 883 1,958 
Other19,397 5,968 2,891 7,788 863 
Total740,723 2,013,578 240,369 155,805 58,450 347,153 
Non-current accrued taxes (including unrecognized tax benefits)(397,634)138,330 (161,929)(251,735)(5,369)(57,691)
Accumulated deferred income taxes and taxes accrued($1,416,201)($2,433,854)($720,097)($365,384)($692,496)($382,931)
2020Entergy ArkansasEntergy LouisianaEntergy MississippiEntergy New OrleansEntergy TexasSystem Energy
 (In Thousands)
Deferred tax liabilities:      
Plant basis differences - net($1,117,948)($2,481,976)($623,796)($83,457)($620,669)($407,125)
Regulatory assets(188,284)(95,135)(22,381)(20,276)(47,684)(56,496)
Nuclear decommissioning trusts/receivables(156,123)(148,040)— — — (131,985)
Pension, net funding(93,486)(95,854)(24,922)(11,564)(19,481)(20,330)
Deferred fuel— (4,210)(1,706)(1,393)— (314)
Other(54,753)(76,735)(27,565)(26,334)(141)(12,521)
Total(1,610,594)(2,901,950)(700,370)(143,024)(687,975)(628,771)
Deferred tax assets:      
Regulatory liabilities273,774 218,278 56,022 31,248 47,991 163,534 
Nuclear decommissioning liabilities123,319 7,767 — (419)121 29,916 
Pension and other post-employment benefits(24,747)72,724 (6,763)(13,997)(17,132)(1,344)
Sale and leaseback— — — — — 102,477 
Accumulated deferred investment tax credit7,971 31,155 2,261 4,197 2,088 9,706 
Provision for allowances and contingencies22,179 7,071 16,799 24,529 (4,094)— 
Power purchase agreements9,662 3,381 1,140 (5,324)(30,932)— 
Unbilled/deferred revenues4,242 (23,382)2,989 877 5,909 — 
Compensation2,264 3,240 1,670 761 1,308 48 
Net operating loss carryforwards119,555 363,806 54,262 26,564 53,052 — 
Capital losses and miscellaneous tax credits— 9,309 — 12,317 — 7,014 
Other16,036 6,958 3,507 8,128 2,232 
Total554,255 700,307 131,887 88,881 60,543 311,353 
Non-current accrued taxes (including unrecognized tax benefits)(229,784)63,121 (78,191)(284,571)(11,990)(42,417)
Accumulated deferred income taxes and taxes accrued($1,286,123)($2,138,522)($646,674)($338,714)($639,422)($359,835)
The Registrant Subsidiaries’ estimated tax attributes carryovers and their expiration dates as of December 31, 2021 are as follows:

 Entergy ArkansasEntergy LouisianaEntergy MississippiEntergy New OrleansEntergy TexasSystem Energy
       
Federal net operating losses before 1/1/2018$— billion$1.7 billion$— billion$0.9 billion$— billion$— billion
Year(s) of expirationN/A2035-2037N/A2037N/AN/A
Federal net operating losses - 1/1/2018 forward$4.5 billion$4.5 billion$2.1 billion$0.7 billion$2.6 billion$— billion
Year(s) of expirationN/AN/AN/AN/AN/AN/A
       
State net operating losses$4.8 billion$7.2 billion$2.3 billion$1.7 billion$— million$— million
Year(s) of expiration2023-2026N/A2038-2041N/AN/AN/A
       
Misc. federal credits$4.7 million$12.3 million$1.8 million$15.3 million$3.1 million$1.5 million
Year(s) of expiration2038-20412035-20412038-20412037-20412036-20412036-2041
       
State credits$— million$— million$1.3 million$—million$2.9 million$9 million
Year(s) of expirationN/AN/A2022-2025N/A20272022-2025

As a result of the accounting for uncertain tax positions, the amount of the deferred tax assets reflected in the financial statements is less than the amount of the tax effect of the federal and state net operating loss carryovers and tax credit carryovers.

Unrecognized tax benefits

Accounting standards establish a “more-likely-than-not” recognition threshold that must be met before a tax benefit can be recognized in the financial statements.  If a tax deduction is taken on a tax return but does not meet the more-likely-than-not recognition threshold, an increase in income tax liability, above what is payable on the tax return, is required to be recorded.  A reconciliation of Entergy’s beginning and ending amount of unrecognized tax benefits is as follows:
 202120202019
 (In Thousands)
Gross balance at January 1$5,699,339 $7,383,154 $7,181,482 
Additions based on tax positions related to the current year101,623 669,207 731,276 
Additions for tax positions of prior years33,419 98,591 151,628 
Reductions for tax positions of prior years (74,413)(935,735)(681,232)
Settlements— (1,515,878)— 
Gross balance at December 315,759,968 5,699,339 7,383,154 
Offsets to gross unrecognized tax benefits:   
Loss and tax credit carryovers(4,987,799)(4,710,214)(5,831,587)
Cash paid to taxing authorities(60,000)(10,000)(10,000)
Unrecognized tax benefits net of unused tax attributes, refund claims and payments (a)$712,169 $979,125 $1,541,567 
(a)Potential tax liability above what is payable on tax returns

The balances of unrecognized tax benefits include $2,256 million, $2,208 million, and $2,421 million as of December 31, 2021, 2020, and 2019, respectively, which, if recognized, would lower the effective income tax rates.  Because of the effect of deferred tax accounting, the remaining balances of unrecognized tax benefits of $3,504 million, $3,491 million, and $4,962 million as of December 31, 2021, 2020, and 2019, respectively, if disallowed, would not affect the annual effective income tax rate but would accelerate the payment of cash to the taxing authority to an earlier period.

Entergy accrues interest expense, if any, related to unrecognized tax benefits in income tax expense.  Entergy’s December 31, 2021, 2020, and 2019 accrued balance for the possible payment of interest is approximately $52 million, $44 million, and $48 million, respectively. Interest (net-of-tax) of $8 million, ($4) million, and $4 million was recorded in 2021, 2020, and 2019, respectively.

A reconciliation of the Registrant Subsidiaries’ beginning and ending amount of unrecognized tax benefits for 2021, 2020, and 2019 is as follows:
2021Entergy ArkansasEntergy LouisianaEntergy MississippiEntergy New OrleansEntergy TexasSystem Energy
 (In Thousands)
Gross balance at January 1, 2021$1,364,635 $640,295 $549,717 $639,546 $521,932 $21,652 
Additions based on tax positions related to the current year30,419 13,437 684 1,050 32,616 1,753 
Additions for tax positions of prior years15,013 9,304 1,504 2,315 1,897 
Reductions for tax positions of prior years(1,573)(58,408)(2,336)(1,105)(4,568)(1,946)
Gross balance at December 31, 20211,408,494 604,628 549,569 639,497 552,295 23,356 
Offsets to gross unrecognized tax benefits:      
Loss and tax credit carryovers(992,643)(604,628)(388,728)(484,899)(540,694)(8,576)
Unrecognized tax benefits net of unused tax attributes and payments$415,851 $— $160,841 $154,598 $11,601 $14,780 

2020Entergy ArkansasEntergy LouisianaEntergy MississippiEntergy New OrleansEntergy TexasSystem Energy
 (In Thousands)
Gross balance at January 1, 2020$1,341,242 $2,381,653 $566,287 $716,773 $21,406 $473,331 
Additions based on tax positions related to the current year (a)9,403 35,681 5,619 2,430 504,362 4,013 
Additions for tax positions of prior years13,400 10,508 1,156 294 799 4,606 
Reductions for tax positions of prior years(11,346)(679,601)(24,173)(80,267)(5,559)(41,466)
Settlements11,936 (1,107,946)828 316 924 (418,832)
Gross balance at December 31, 20201,364,635 640,295 549,717 639,546 521,932 21,652 
Offsets to gross unrecognized tax benefits:      
Loss and tax credit carryovers(1,112,628)(640,295)(465,679)(451,922)(507,720)(7,413)
Unrecognized tax benefits net of unused tax attributes and payments$252,007 $— $84,038 $187,624 $14,212 $14,239 
2019Entergy ArkansasEntergy LouisianaEntergy MississippiEntergy New OrleansEntergy TexasSystem Energy
 (In Thousands)
Gross balance at January 1, 2019$1,298,662 $2,400,171 $508,765 $686,687 $17,802 $467,487 
Additions based on tax positions related to the current year84,335 28,705 68,594 40,676 2,312 5,496 
Additions for tax positions of prior years20,399 25,090 1,651 489 1,299 2,186 
Reductions for tax positions of prior years(62,154)(72,313)(12,723)(11,079)(7)(1,838)
Gross balance at December 31, 20191,341,242 2,381,653 566,287 716,773 21,406 473,331 
Offsets to gross unrecognized tax benefits:      
Loss and tax credit carryovers(1,134,187)(1,573,257)(506,976)(445,430)(3,944)(8,392)
Unrecognized tax benefits net of unused tax attributes and payments$207,055 $808,396 $59,311 $271,343 $17,462 $464,939 

(a)The primary additions for Entergy Texas in 2020 are related to the mark-to-market treatment discussed in “Other Tax Matters - Tax Accounting Methods” below.

The Registrant Subsidiaries’ balances of unrecognized tax benefits included amounts which, if recognized, would have reduced income tax expense as follows:
December 31,
 202120202019
 (In Millions)
Entergy Arkansas$262.1 $259.3 $203.3 
Entergy Louisiana$66.3 $63.8 $556.3 
Entergy Mississippi$51.7 $50.7 $1.9 
Entergy New Orleans$228.6 $203.5 $242.7 
Entergy Texas$2.6 $6.1 $5.7 
System Energy$1.7 $0.5 $— 

Accrued balances for the possible payment of interest related to unrecognized tax benefits are as follows:
December 31,
 202120202019
 (In Millions)
Entergy Arkansas$2.7 $2.3 $3.1 
Entergy Louisiana$3.7 $3.4 $14.2 
Entergy Mississippi$2.4 $1.9 $1.7 
Entergy New Orleans$5.2 $3.9 $4.7 
Entergy Texas$1.1 $0.9 $1.1 
System Energy$12.1 $11.9 $14.5 
The Registrant Subsidiaries record interest and penalties related to unrecognized tax benefits in income tax expense.  No penalties were recorded in 2021, 2020, and 2019. Interest (net-of-tax) was recorded as follows:
202120202019
(In Millions)
Entergy Arkansas$0.4 ($0.8)$1.4 
Entergy Louisiana$0.3 ($10.8)($3.7)
Entergy Mississippi$0.5 $0.2 $0.5 
Entergy New Orleans$1.3 ($0.8)$2.0 
Entergy Texas$0.2 ($0.2)$0.2 
System Energy$0.2 ($2.6)$1.3 

Income Tax Audits

Entergy and its subsidiaries file U.S. federal and various state income tax returns.  IRS examinations are complete for years before 2016. All state taxing authorities’ examinations are complete for years before 2014. Entergy regularly defends its positions and works with the IRS to resolve audits.  The resolution of audit issues could result in significant changes to the amounts of unrecognized tax benefits in the next twelve months.

2014-2015 IRS Audit

The IRS completed its examination of the 2014 and 2015 tax years and issued its 2014-2015 RAR in November 2020. Entergy agreed to all proposed adjustments contained in the RAR. Entergy and the Registrant Subsidiaries recorded the effects of the adjustments associated with the audit in 2020.

In October 2015 two of Entergy’s Louisiana utilities, Entergy Gulf States Louisiana and Entergy Louisiana, combined their businesses into a legal entity which is identified as Entergy Louisiana herein. The structure of the business combination required Entergy to recognize a gain for income tax purposes which resulted in an increase in the tax basis of the assets for Entergy Louisiana. This resulted in recognition in 2015 of a $334 million permanent difference and income tax benefit, net of the uncertain tax position recorded on the transaction.

Primarily related to resolution of the business combination issues, completion of the 2014-2015 IRS audit in 2020 resulted in a $230 million reduction to deferred income tax expense for Entergy. This reduction to deferred income tax expense includes: Entergy Louisiana reversing its provision for uncertain tax position with respect to the business combination, which resulted in a reduction to deferred income tax expense of $383 million; Entergy Corporation recording an increase to deferred tax expense of $61 million and Entergy Wholesale Commodities recording an increase to deferred tax expense of $105 million from the re-measurement of deferred tax assets associated with the resolved uncertain tax position; and miscellaneous other individually insignificant benefits totaling $13 million.

The completion of the 2014-2015 tax audit also resulted in a $31 million reduction to income tax expense associated with Entergy Louisiana’s method of accounting related to the adoption of tangible property regulations. As a result of the settlement of the tangible property regulation tax position, Entergy Louisiana was required to record a $33 million ($24 million net-of-tax) regulatory charge and a corresponding regulatory liability to reflect its obligation to customers pursuant to a prior regulatory settlement.

Finally, upon completion of the 2014-2015 tax audit, Entergy New Orleans recorded a reduction to income tax expense of $8 million associated with claims for mark-to-market deductions.

In the first quarter 2020, Entergy and the IRS agreed on the treatment of funds received by Entergy Louisiana in conjunction with the Act 55 financing of Hurricane Isaac storm costs, which resulted in a net reduction
of income tax expense of approximately $32 million. As a result of the settlement, the position was partially sustained, and Entergy Louisiana recorded a reduction of income tax expense of approximately $58 million primarily due to the reversal of a provision for uncertain tax positions in excess of the agreed-upon settlement. As a result of the IRS settlement, Entergy Louisiana recorded a $29 million ($21 million net-of-tax) regulatory charge and a corresponding regulatory liability to reflect its obligation to customers pursuant to the LPSC Hurricane Isaac Act 55 financing order.

Additional effects of the completion of the 2014-2015 IRS tax audit are discussed below within Tax Accounting Methods.

Other Tax Matters

Tax Cuts and Jobs Act (TCJA)

The most significant effect of the TCJA for Entergy and the Registrant Subsidiaries was the change in the federal corporate income tax rate from 35% to 21%, effective January 1, 2018.

TCJA also limited the deduction for net business interest expense to 30 percent of adjusted taxable income, which is similar to earnings before interest, taxes, depreciation, and amortization. The limitation does not apply to interest expense that is properly allocable to a trade or business classified as a regulated public utility. This was further modified by a temporary provision of the CARES Act resulting in an increase of the adjusted taxable income limitation from 30% to 50% for tax years that begin in 2019 or 2020.

The IRS issued final regulations which are effective for Entergy beginning with the 2021 tax year. The regulations provide that if 90% of a tax group’s consolidated assets consist of regulated utility property, the entire consolidated tax group will be treated as a regulated public utility and all of the consolidated group’s interest expense will be currently tax deductible. Entergy expects that this provision will continue to apply to Entergy’s business operations making the application of this limitation to Entergy less likely. The provision has not resulted in Entergy having to report any significant business interest expense limitations on its tax returns.

With respect to the federal corporate income tax rate change from 35% to 21% in 2017, Entergy and the Registrant Subsidiaries recorded a regulatory liability associated with the decrease in the net accumulated deferred income tax liability, which is often referred to as “excess ADIT,” a significant portion of which has been paid to customers in 2019, 2020 and 2021 in the form of lower rates. Entergy’s December 31, 2021 and December 31, 2020 balance sheets reflect a regulatory liability of $1.3 billion and $1.6 billion, respectively, as a result of the re-measurement of deferred tax assets and liabilities from the income tax rate change, amortization of excess ADIT, and payments to customers during 2019, 2020 and 2021. Entergy’s regulatory liability for income taxes includes a gross-up at the applicable tax rate because of the effect that excess ADIT has on the ratemaking formula. The regulatory liability for income taxes includes the effect of a) the reduction of the net deferred tax liability resulting in excess ADIT, and b) the tax gross-up of excess ADIT. The Registrant Subsidiaries’ December 31, 2021 and December 31, 2020 balance sheets reflect net regulatory liabilities for income taxes as follows:
20212020
(In Millions)
Entergy Arkansas$432 $467 
Entergy Louisiana$338 $479 
Entergy Mississippi$212 $224 
Entergy New Orleans$42 $59 
Entergy Texas$171 $205 
System Energy$113 $152 
Excess ADIT is generally classified into two categories: 1) the portion that is subject to the normalization requirements of the TCJA, i.e., “protected”, and 2) the portion that is not subject to such normalization provisions, referred to as “unprotected”. The TCJA provides that the normalization method of accounting for income taxes is required for excess ADIT associated with public utility property. The TCJA provides for the use of the average rate assumption method (ARAM) for the determination of the timing of the return of excess ADIT associated with such property. Under ARAM, the excess ADIT is reduced over the remaining life of the asset. Remaining asset lives vary for each Registrant Subsidiary, but the average life of public utility property is typically 30 years or longer. Entergy will amortize the protected portion of the excess ADIT in conformity with the normalization requirements. The Registrant Subsidiaries’ net regulatory liability for income taxes as of December 31, 2021 and December 31, 2020, includes protected excess ADIT as follows:
20212020
(In Millions)
Entergy Arkansas$463 $490 
Entergy Louisiana$669 $721 
Entergy Mississippi$237 $248 
Entergy New Orleans$56 $61 
Entergy Texas$208 $215 
System Energy$148 $173 

Payment of the unprotected excess accumulated deferred income taxes results in a reduction in the regulatory liability for income taxes and a corresponding reduction in income tax expense. This has a significant effect on the effective tax rate for the period as compared to the statutory tax rate. The Registrant Subsidiaries’ net regulatory liability for income taxes as of December 31, 2021 and December 31, 2020, includes unprotected excess ADIT as follows:
20212020
(In Millions)
Entergy Arkansas$12 $11 
Entergy Louisiana$148 $223 
Entergy New Orleans$— $3 
Entergy Texas$26 $54 
System Energy$— $16 

The return of unprotected excess accumulated deferred income taxes reduced Entergy’s and the Registrant Subsidiaries’ regulatory liability for income taxes as follows for 2021 and 2020:
20212020
(In Millions)
Entergy$88 $74 
Entergy Arkansas$8 $8 
Entergy Louisiana$33 $31 
Entergy New Orleans$1 $6 
Entergy Texas$28 $29 
System Energy$18 $— 

In addition to the protected and unprotected excess ADIT amounts, the net regulatory liability for income taxes includes other regulatory assets and liabilities for income taxes associated with AFUDC, which is described in Note 1 to the financial statements.
Included in the effect of the computation of the changes in deferred tax assets and liabilities is the recognition threshold and measurement of uncertain tax positions resulting in unrecognized tax benefits. The final economic outcome of such unrecognized tax benefits is generally the result of a negotiated settlement with the IRS that often differs from the amount that is recorded as realizable under GAAP. The intrinsic uncertainty with respect to all such tax positions means that the difference between current estimates of such amounts likely to be realized and actual amounts realized upon settlement may have an effect on income tax expense and the regulatory liability for income taxes in future periods.

Entergy anticipates that the effect of TCJA may continue to have ramifications that require adjustments in the future as certain events occur. These events include: 1) IRS audit adjustments to or amendments of federal and state income tax returns that include modifications to the computation of taxable income resulting from TCJA; and 2) additional guidance, interpretations, or rulings by the U.S. Department of the Treasury or the IRS. The potential exists for these types of events to result in future tax expense adjustments because of the difference in the federal corporate income tax rate between past and future periods and the effect of the tax rate change on ratemaking. In turn, these events also could potentially affect the regulatory liability for income taxes.

Coronavirus Aid, Relief, and Economic Security Act

In response to the economic impacts of the COVID-19 pandemic, President Trump signed the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) into law on March 27, 2020. The CARES Act provisions that result in the most significant opportunities for tax relief to Entergy and the Registrant Subsidiaries are (i) permitting a five-year carryback of 2018-2020 NOLs, (ii) removing the 80 percent limitation on NOLs carried to tax years beginning before 2021, (iii) increasing the limitation on interest expense deductibility for 2019 and 2020, (iv) accelerating available refunds for minimum tax credit carryforwards, modifying limitations on charitable contributions during 2020, and (v) delaying the payment of employer payroll taxes. Entergy deferred approximately $64 million of 2020 payroll tax payments, payable in equal installments over two years. The initial installment of $32 million was paid in December 2021. The second installment will be paid in December 2022.

Entergy Wholesale Commodities Restructuring

In the fourth quarter 2019, two separate events occurred resulting in a reduction of tax expense of $174 million. In November 2019 an Entergy Wholesale Commodities subsidiary recognized a reduction in income tax expense of $18 million in connection with the accounting method on power contracts associated with the Palisades nuclear power station. Additionally, Entergy’s ownership of Indian Point 2 and Indian Point 3 was restructured. The restructuring required Entergy to recognize Indian Point 2 and Indian Point 3 nuclear decommissioning liabilities for income tax purposes resulting in a tax accounting permanent difference that reduced income tax expense, net of unrecognized tax benefits, by $156 million. The accrual of the nuclear decommissioning liabilities also required Entergy to recognize a gain for income tax purposes, a portion of which resulted in an increase in the tax basis of the assets. Recognition of the gain and the increase in the tax basis of the assets represents a tax accounting temporary difference.

Immediately prior to the restructuring, through its ownership of Indian Point 2 and Indian Point 3, Entergy donated property to Stony Brook University and recognized an associated tax deduction resulting in a decrease to tax expense of $19 million.

In the fourth quarter 2020, Entergy’s ownership of Palisades was restructured. The restructuring required Entergy to recognize Palisades’ nuclear decommissioning liability for income tax purposes resulting in a tax accounting permanent difference that reduced income tax expense, net of unrecognized tax benefits, by $9.2 million. The accrual of the nuclear decommissioning liability also required Entergy to recognize a gain for income tax purposes, a portion of which resulted in an increase in the tax basis of the assets. Recognition of the gain and the increase in the tax basis of the assets represents a tax accounting temporary difference.
Tax Accounting Methods

In the fourth quarter 2015, System Energy and Entergy Louisiana adopted a new method of accounting for income tax return purposes in which their nuclear decommissioning costs will be treated as production costs of electricity includable in cost of goods sold. The new method resulted in a reduction of taxable income of $1.2 billion for System Energy and $2.2 billion for Energy Louisiana.

In conjunction with the 2014-2015 IRS audit discussed above, the IRS issued proposed adjustments concerning the nuclear decommissioning tax position allowing System Energy to include $102 million of its decommissioning liability in cost of goods sold, and Entergy Louisiana to include $221 million of its decommissioning liability in cost of goods sold. Entergy, System Energy, and Entergy Louisiana agreed to the proposed adjustments included in the RAR.

As a result of System Energy being allowed to include part of its decommissioning liability in cost of goods sold, System Energy and Entergy recorded a deferred tax liability of $26 million. System Energy also recorded federal and state taxes payable of $402 million. However, on a consolidated basis, Entergy utilized tax loss carryovers to offset the federal taxable income adjustment and did not record federal taxes payable as a result of the outcome of this uncertain tax position.

As a result of Entergy Louisiana being allowed to include part of its decommissioning liability in cost of goods sold, Entergy Louisiana and Entergy recorded a deferred tax liability of $60 million. Both Entergy Louisiana and Entergy utilized tax loss carryovers to offset the taxable income adjustment and accordingly did not record taxes payable as a result of the outcome of this uncertain tax position.

The partial disallowance of this uncertain tax position to include the decommissioning liability in cost of goods sold resulted in a $1.5 billion decrease in the balance of unrecognized tax benefits related to federal and state taxes for Entergy. Additionally, both System Energy and Entergy Louisiana recorded a reduction to their balances of unrecognized tax benefits for federal and state taxes of $461 million and $1.1 billion, respectively.

Entergy Arkansas adopted the same method of accounting for its nuclear decommissioning costs which resulted in a $1.8 billion reduction in taxable income on its 2018 tax return.

In 2016, Entergy Louisiana elected mark-to-market income tax treatment for various wholesale electric power purchase and sale agreements, including Entergy Louisiana’s contract to purchase electricity from the Vidalia hydroelectric facility and from System Energy under the Unit Power Sales Agreement. The election resulted in a $2.2 billion deductible temporary difference. In 2017, Entergy New Orleans also elected mark-to-market income tax treatment for wholesale electric contracts which resulted in a $1.1 billion deductible temporary difference. In 2018, Entergy Arkansas and Entergy Mississippi accrued deductible temporary differences related to mark-to-market tax accounting for wholesale electric contracts of $2.1 billion and $1.9 billion, respectively. Additionally, in 2020, Entergy Texas elected mark-to-market income tax treatment for wholesale electric power purchase and sale agreements which resulted in a $2.5 billion deductible temporary difference.

Arkansas and Louisiana Corporate Income Tax Rate Changes

In April 2019 and December 2021 the State of Arkansas enacted corporate income tax law changes that phased in rate reductions from the former rate of 6.5% to 6.2% in 2021, 5.9% in 2022, and 5.7% in 2023.    As a result of the 2019 rate reduction, Entergy Arkansas computed a regulatory liability for income taxes as of December 31, 2020 of approximately $21 million, which includes a tax gross-up related to the treatment of income taxes in the retail and wholesale ratemaking formulas and has been included in the appropriate rate mechanisms. Entergy Arkansas recorded an incremental regulatory liability of $11 million associated with the rate reduction enacted in December 2021. The Arkansas tax law enactment also phases in an increase to the net operating loss carryover period from five to ten years.
Pursuant to legislation enacted in 2021 and approved by Louisiana citizens by amendment to the state constitution, beginning January 1, 2022, federal income taxes paid will no longer be deductible for state income tax purposes, and the top Louisiana corporate income tax rate will be reduced from 8% to 7.5%. As a result of this change in Louisiana tax law, the Louisiana applicable tax rate increased by 0.85%. Accordingly, deferred tax assets and liabilities were adjusted to reflect the new applicable federal and state rates. Legislation enacted in 2021 also provides that Louisiana net operating losses generally have an indefinite carryover period.

Entergy recorded a net increase to its deferred tax asset of $27 million. Entergy Louisiana and Entergy New Orleans recorded net increases to their deferred tax liabilities before consideration of the tax gross-up of $77 million and $8 million, respectively, which were offset by regulatory assets for income taxes. Therefore, these increases had no effect on tax expense. However, the increase of deferred tax assets associated with certain assets reduced tax expense for Entergy Louisiana and Entergy New Orleans by $6 million and $2 million, respectively.

Consolidated Income Tax Return of Entergy Corporation

In September 2019, Entergy Utility Holding Company, LLC and its regulated, wholly-owned subsidiaries including Entergy Arkansas, Entergy Louisiana, Entergy Mississippi, and Entergy New Orleans, became eligible to and joined the Entergy Corporation consolidated federal income tax group.  As a result of these four Utility operating companies re-joining the Entergy Corporation consolidated tax return group, Entergy was able to recognize a $41 million deferred tax asset associated with a previously unrecognized net operating loss carryover.

In September 2019, Entergy Texas issued $35 million of 5.375% Series A preferred stock with a liquidation value of $25 per share resulting in the disaffiliation and de-consolidation of Entergy Texas from the consolidated federal income tax return of Entergy Corporation.  These changes will not affect the accrual or allocation of income taxes for the Registrant Subsidiaries. See Note 6 to the financial statements for discussion of the preferred stock issuance.

Vermont Yankee

The Vermont Yankee transaction resulted in Entergy generating a net deferred tax asset in January 2019.  The deferred tax asset could not be fully realized by Entergy in the first quarter 2019; accordingly, Entergy accrued a net tax expense of $29 million on the disposition of Vermont Yankee. See Note 14 to the financial statements for discussion of the Vermont Yankee transaction.

Stock Compensation

In accordance with stock compensation accounting rules, Entergy and the Registrant Subsidiaries recognized excess tax deductions as a reduction of income tax expense in the first quarter 2020. Due to the vesting and exercise of certain Entergy stock-based awards, Entergy recorded a permanent tax reduction of approximately $24.7 million, including $4.8 million for Entergy Arkansas, $8.6 million for Entergy Louisiana, $2.7 million for Entergy Mississippi, $1.5 million for Entergy New Orleans, $2.7 million for Entergy Texas, and $1.3 million for System Energy.
Entergy Louisiana [Member]  
Income Taxes INCOME TAXES (Entergy Corporation, Entergy Arkansas, Entergy Louisiana, Entergy Mississippi, Entergy New Orleans, Entergy Texas, and System Energy)
Income taxes for 2021, 2020, and 2019 for Entergy Corporation and Subsidiaries consist of the following:
 202120202019
 (In Thousands)
Current:   
Federal($5,003)$5,807 ($14,416)
State(8,995)57,939 6,535 
Total(13,998)63,746 (7,881)
Deferred and non-current - net205,891 (190,635)(155,956)
Investment tax credit adjustments - net(519)5,383 (5,988)
Income taxes$191,374 ($121,506)($169,825)

Income taxes for 2021, 2020, and 2019 for Entergy’s Registrant Subsidiaries consist of the following:
2021Entergy ArkansasEntergy LouisianaEntergy MississippiEntergy New OrleansEntergy TexasSystem Energy
(In Thousands)
Current:      
Federal($20,285)($24,053)($5,868)($6,724)($189)$29,416 
State529 2,459 (11,506)(413)1,261 (10,258)
Total(19,756)(21,594)(17,374)(7,137)1,072 19,158 
Deferred and non-current - net96,180 146,786 60,861 12,870 25,087 (25,229)
Investment tax credit adjustments - net(1,229)(4,783)1,836 203 (633)4,094 
Income taxes$75,195 $120,409 $45,323 $5,936 $25,526 ($1,977)

2020Entergy ArkansasEntergy LouisianaEntergy MississippiEntergy New OrleansEntergy TexasSystem Energy
 (In Thousands)
Current:      
Federal($44,627)$62,728 ($14,580)$293 ($5,603)$372,206 
State(2,563)4,457 (1,316)(303)2,658 55,551 
Total(47,190)67,185 (15,896)(10)(2,945)427,757 
Deferred and non-current - net96,195 (444,647)43,640 (18,153)6,619 (405,928)
Investment tax credit adjustments - net(1,228)(4,862)(554)13,956 (632)(1,286)
Income taxes$47,777 ($382,324)$27,190 ($4,207)$3,042 $20,543 
2019Entergy ArkansasEntergy LouisianaEntergy MississippiEntergy New OrleansEntergy TexasSystem Energy
 (In Thousands)
Current:      
Federal($14,549)($20,173)($8,939)($5,822)$16,035 $16,256 
State(714)(735)5,823 1,856 663 (2,831)
Total(15,263)(20,908)(3,116)(3,966)16,698 13,425 
Deferred and non-current - net(30,278)147,453 34,579 4,248 (69,963)422 
Investment tax credit adjustments - net(1,228)(4,922)(597)(96)(631)1,502 
Income taxes($46,769)$121,623 $30,866 $186 ($53,896)$15,349 

Total income taxes for Entergy Corporation and Subsidiaries differ from the amounts computed by applying the statutory income tax rate to income before income taxes.  The reasons for the differences for the years 2021, 2020, and 2019 are:
 202120202019
 (In Thousands)
Net income attributable to Entergy Corporation$1,118,492 $1,388,334 $1,241,226 
Preferred dividend requirements of subsidiaries227 18,319 17,018 
Consolidated net income1,118,719 1,406,653 1,258,244 
Income taxes191,374 (121,506)(169,825)
Income before income taxes$1,310,093 $1,285,147 $1,088,419 
Computed at statutory rate (21%)$275,120 $269,881 $228,568 
Increases (reductions) in tax resulting from:   
State income taxes net of federal income tax effect79,273 60,087 61,791 
Regulatory differences - utility plant items(57,556)(53,229)(45,336)
Equity component of AFUDC(14,799)(25,080)(30,444)
Amortization of investment tax credits(7,695)(8,386)(8,093)
Flow-through / permanent differences(5,585)11,099 (2,059)
Amortization of excess ADIT (a)(66,478)(59,629)(205,614)
Arkansas and Louisiana Rate Changes (b)(27,108)— — 
IRS audit adjustment (d)— (301,041)— 
Entergy Wholesale Commodities restructuring (c)— (9,223)(173,725)
Stock compensation (e)— (25,591)— 
Charitable contribution (c)— — (19,101)
Net operating loss recognition— — (41,427)
Provision for uncertain tax positions16,533 15,208 7,332 
Valuation allowance(2,600)— 59,345 
Other - net2,269 4,398 (1,062)
Total income taxes as reported$191,374 ($121,506)($169,825)
Effective Income Tax Rate14.6 %(9.5 %)(15.6 %)

(a)See “Other Tax Matters - Tax Cuts and Jobs Act” below for discussion of the amortization of excess accumulated deferred income taxes (ADIT) in 2019, 2020, and 2021 and the tax legislation enactment in 2017.
(b)See “Arkansas and Louisiana Corporate Income Tax Rate Changes” below for details.
(c)See Other Tax Matters - Entergy Wholesale Commodities Restructuring” below for discussion of the Entergy Wholesale Commodities restructuring in 2019, the ownership of Palisades restructuring in 2020, and the charitable contribution in 2019.
(d)See “Income Tax Audits - 2014-2015 IRS Audit” below for discussion of the resolution of the audit in 2020.
(e)See “Other Tax Matters - Stock Compensation” below for discussion of excess tax deductions.

Total income taxes for the Registrant Subsidiaries differ from the amounts computed by applying the statutory income tax rate to income before taxes.  The reasons for the differences for the years 2021, 2020, and 2019 are:
2021Entergy ArkansasEntergy LouisianaEntergy MississippiEntergy New OrleansEntergy TexasSystem Energy
 (In Thousands)
Net income$298,484 $653,984 $166,834 $31,798 $228,824 $106,814 
Income taxes75,195 120,409 45,323 5,936 25,526 (1,977)
Pretax income$373,679 $774,393 $212,157 $37,734 $254,350 $104,837 
Computed at statutory rate (21%)$78,473 $162,623 $44,553 $7,924 $53,413 $22,016 
Increases (reductions) in tax resulting from:     
State income taxes net of federal income tax effect19,633 41,030 9,305 2,579 1,553 5,385 
Regulatory differences - utility plant items(16,078)(14,123)(8,133)(4,332)(2,115)(12,776)
Equity component of AFUDC(3,207)(6,016)(1,701)(498)(2,077)(1,300)
Amortization of investment tax credits(1,201)(4,729)64 (56)(617)(1,155)
Flow-through / permanent differences(814)(2,655)124 1,559 (475)(1,235)
Amortization of excess ADIT (a)(5,845)(24,323)— (1,028)(21,929)(13,354)
Arkansas and Louisiana Rate Changes (b)398 (6,126)395 (1,569)216 115 
Non-taxable dividend income— (26,801)— — — — 
Provision for uncertain tax positions353 300 465 1,200 (2,716)200 
Valuation Allowance2,766 — — — — — 
Other - net717 1,229 251 157 273 127 
Total income taxes as reported$75,195 $120,409 $45,323 $5,936 $25,526 ($1,977)
Effective Income Tax Rate20.1 %15.5 %21.4 %15.7 %10.0 %(1.9 %)
2020Entergy ArkansasEntergy LouisianaEntergy MississippiEntergy New OrleansEntergy TexasSystem Energy
 (In Thousands)
Net income$245,232 $1,082,352 $140,583 $49,338 $215,073 $99,131 
Income taxes47,777 (382,324)27,190 (4,207)3,042 20,543 
Pretax income$293,009 $700,028 $167,773 $45,131 $218,115 $119,674 
Computed at statutory rate (21%)$61,532 $147,006 $35,232 $9,478 $45,804 $25,132 
Increases (reductions) in tax resulting from:
State income taxes net of federal income tax effect16,256 38,182 6,917 2,606 1,460 5,524 
Regulatory differences - utility plant items(8,034)(23,819)(7,441)(3,442)(7,673)(2,821)
Equity component of AFUDC(3,154)(8,012)(1,412)(1,331)(9,255)(1,916)
Amortization of investment tax credits(1,201)(4,811)(540)(61)(617)(1,155)
Flow-through / permanent differences(2,219)1,404 (102)498 766 (421)
Amortization of excess ADIT (a)(6,011)(26,293)18 (4,564)(22,780)— 
Stock compensation (d)(4,952)(9,004)(2,763)(1,526)(2,842)(1,300)
IRS audit adjustment (c)(6,351)(471,702)(3,768)(6,819)(2,091)(2,925)
Non-taxable dividend income— (26,795)— — — — 
Provision for uncertain tax positions1,200 300 800 800 — 300 
Other - net711 1,220 249 154 270 125 
Total income taxes as reported$47,777 ($382,324)$27,190 ($4,207)$3,042 $20,543 
Effective Income Tax Rate16.3 %(54.6 %)16.2 %(9.3 %)1.4 %17.2 %

2019Entergy ArkansasEntergy LouisianaEntergy MississippiEntergy New OrleansEntergy TexasSystem Energy
 (In Thousands)
Net income$262,964 $691,537 $119,925 $52,629 $159,397 $99,120 
Income taxes(46,769)121,623 30,866 186 (53,896)15,349 
Pretax income$216,195 $813,160 $150,791 $52,815 $105,501 $114,469 
Computed at statutory rate (21%)$45,401 $170,764 $31,666 $11,091 $22,155 $24,039 
Increases (reductions) in tax resulting from:      
State income taxes net of federal income tax effect15,954 42,854 5,563 3,443 360 5,134 
Regulatory differences - utility plant items(10,627)(19,421)(5,556)(1,532)(1,987)(6,213)
Equity component of AFUDC(3,255)(15,545)(1,755)(2,088)(5,973)(1,829)
Amortization of investment tax credits(1,201)(4,871)(160)(88)(617)(1,155)
Flow-through / permanent differences696 439 160 (741)560 (500)
Amortization of excess ADIT (a)(90,921)(28,531)203 (11,724)(69,091)(5,550)
Non-taxable dividend income— (26,795)— — — — 
Provision for uncertain tax positions(3,517)1,519 500 1,672 430 1,300 
Other - net701 1,210 245 153 267 123 
Total income taxes as reported($46,769)$121,623 $30,866 $186 ($53,896)$15,349 
Effective Income Tax Rate(21.6 %)15.0 %20.5 %0.4 %(51.1 %)13.4 %
(a)See “Other Tax Matters - Tax Cuts and Jobs Act” below for discussion of the amortization of excess accumulated deferred income taxes (ADIT) in 2019, 2020 and 2021 and the tax legislation enactment in 2017.
(b)See “Arkansas and Louisiana Corporate Income Tax Rate Changes” below for details.
(c)See “Income Tax Audits - 2014-2015 IRS Audit” below for discussion of the resolution of the audit in 2020.
(d)See “Other Tax Matters - Stock Compensation” below for discussion of excess tax deductions.


Significant components of accumulated deferred income taxes and taxes accrued for Entergy Corporation and Subsidiaries as of December 31, 2021 and 2020 are as follows:
 
 20212020
 (In Thousands)
Deferred tax liabilities:  
Plant basis differences - net($6,136,563)($4,795,422)
Regulatory assets(930,244)(429,996)
Nuclear decommissioning trusts/receivables(656,185)(1,188,235)
Pension, net regulatory asset(322,788)(327,445)
Combined unitary state taxes(7,255)(7,723)
Unbilled/deferred revenues— (9,152)
Accumulated storm damage provision(207,243)— 
Deferred fuel(85,310)(7,667)
Other(341,450)(549,355)
Total(8,687,038)(7,314,995)
Deferred tax assets:  
Nuclear decommissioning liabilities278,136 968,464 
Regulatory liabilities1,318,381 791,927 
Pension and other post-employment benefits208,128 278,486 
Sale and leaseback102,474 102,477 
Compensation79,798 89,279 
Accumulated deferred investment tax credit57,986 57,379 
Provision for allowances and contingencies82,286 71,598 
Power purchase agreements55,259 352,019 
Unbilled/deferred revenues26,683 — 
Net operating loss carryforwards2,868,424 1,580,109 
Capital losses and miscellaneous tax credits11,111 21,291 
Valuation allowance(325,239)(328,581)
Other200,032 230,291 
Total4,963,459 4,214,739 
Non-current accrued taxes (including unrecognized tax benefits)(929,032)(1,185,227)
Accumulated deferred income taxes and taxes accrued($4,652,611)($4,285,483)
Entergy’s estimated tax attributes carryovers and their expiration dates as of December 31, 2021 are as follows:
Carryover DescriptionCarryover AmountYear(s) of expiration
   
Federal net operating losses before 1/1/2018$6.2 billion2023-2027
Federal net operating losses - 1/1/2018 forward$21.1 billionN/A
State net operating losses$7.4 billion2022-2041
State net operating losses with no expiration$16.7 billionN/A
Federal and state charitable contributions$460.8 million2022-2026
Miscellaneous federal and state credits$73.1 million2022-2041

As a result of the accounting for uncertain tax positions, the amount of the deferred tax assets reflected in the financial statements is less than the amount of the tax effect of the federal and state net operating loss carryovers, tax credit carryovers, and other tax attributes reflected on income tax returns. Entergy evaluates the available positive and negative evidence to estimate whether sufficient future taxable income of the appropriate character will be generated to realize the benefits of existing deferred tax assets. When the evaluation indicates that Entergy will not be able to realize the existing benefits, a valuation allowance is recorded to reduce deferred tax assets to the realizable amount.

Because it is more likely than not that the benefits from certain state net operating losses and other deferred tax assets will not be utilized, valuation allowances totaling $325 million as of December 31, 2021 and $329 million as of December 31, 2020 have been provided on the deferred tax assets related to federal and state jurisdictions in which Entergy does not currently expect to be able to utilize certain separate company tax return attributes, preventing realization of such deferred tax assets. As a result of incurring costs related to Hurricane Ida restoration, certain Utility operating companies are entitled to an accelerated tax deduction which generated a taxable loss in various taxing jurisdictions. This accelerated deduction has impaired the realizability of a limited term carryover tax attribute. Accordingly, the impairment contributed to the activity reflected for the valuation allowance disclosed above.
Significant components of accumulated deferred income taxes and taxes accrued for the Registrant Subsidiaries as of December 31, 2021 and 2020 are as follows:
2021Entergy ArkansasEntergy LouisianaEntergy MississippiEntergy New OrleansEntergy TexasSystem Energy
 (In Thousands)
Deferred tax liabilities:      
Plant basis differences - net($1,158,523)($3,429,473)($681,968)($192,660)($654,252)($433,874)
Regulatory assets(226,687)(530,274)(34,799)(30,694)(45,470)(61,205)
Nuclear decommissioning trusts/receivables(175,882)(186,382)— — — (153,610)
Pension, net regulatory asset(92,881)(93,681)(22,253)(11,429)(19,914)(18,033)
Deferred fuel(27,497)(13,686)(30,409)(1,600)(10,139)(49)
Accumulated storm damage provision— (193,967)— — (13,276)— 
Other(77,820)(138,299)(29,108)(33,071)(2,526)(5,622)
Total(1,759,290)(4,585,762)(798,537)(269,454)(745,577)(672,393)
Deferred tax assets:      
Regulatory liabilities310,256 634,184 59,418 36,057 55,022 224,036 
Nuclear decommissioning liabilities123,568 (909)(433)94 9,432 
Pension and other post-employment benefits(26,577)73,006 (7,793)(16,090)(18,793)(1,925)
Sale and leaseback— — — — — 102,474 
Accumulated deferred investment tax credit7,518 30,666 2,723 4,391 1,958 10,729 
Provision for allowances and contingencies24,829 21,768 10,236 5,559 7,730 — 
Power purchase agreements— — 1,140 — (1,202)— 
Unbilled/deferred revenues3,331 9,919 2,306 971 10,196 — 
Compensation3,347 5,288 2,181 1,036 1,618 447 
Net operating loss carryforwards275,054 1,228,547 166,008 105,549 81 — 
Capital losses and miscellaneous tax credits— 5,141 1,258 10,977 883 1,958 
Other19,397 5,968 2,891 7,788 863 
Total740,723 2,013,578 240,369 155,805 58,450 347,153 
Non-current accrued taxes (including unrecognized tax benefits)(397,634)138,330 (161,929)(251,735)(5,369)(57,691)
Accumulated deferred income taxes and taxes accrued($1,416,201)($2,433,854)($720,097)($365,384)($692,496)($382,931)
2020Entergy ArkansasEntergy LouisianaEntergy MississippiEntergy New OrleansEntergy TexasSystem Energy
 (In Thousands)
Deferred tax liabilities:      
Plant basis differences - net($1,117,948)($2,481,976)($623,796)($83,457)($620,669)($407,125)
Regulatory assets(188,284)(95,135)(22,381)(20,276)(47,684)(56,496)
Nuclear decommissioning trusts/receivables(156,123)(148,040)— — — (131,985)
Pension, net funding(93,486)(95,854)(24,922)(11,564)(19,481)(20,330)
Deferred fuel— (4,210)(1,706)(1,393)— (314)
Other(54,753)(76,735)(27,565)(26,334)(141)(12,521)
Total(1,610,594)(2,901,950)(700,370)(143,024)(687,975)(628,771)
Deferred tax assets:      
Regulatory liabilities273,774 218,278 56,022 31,248 47,991 163,534 
Nuclear decommissioning liabilities123,319 7,767 — (419)121 29,916 
Pension and other post-employment benefits(24,747)72,724 (6,763)(13,997)(17,132)(1,344)
Sale and leaseback— — — — — 102,477 
Accumulated deferred investment tax credit7,971 31,155 2,261 4,197 2,088 9,706 
Provision for allowances and contingencies22,179 7,071 16,799 24,529 (4,094)— 
Power purchase agreements9,662 3,381 1,140 (5,324)(30,932)— 
Unbilled/deferred revenues4,242 (23,382)2,989 877 5,909 — 
Compensation2,264 3,240 1,670 761 1,308 48 
Net operating loss carryforwards119,555 363,806 54,262 26,564 53,052 — 
Capital losses and miscellaneous tax credits— 9,309 — 12,317 — 7,014 
Other16,036 6,958 3,507 8,128 2,232 
Total554,255 700,307 131,887 88,881 60,543 311,353 
Non-current accrued taxes (including unrecognized tax benefits)(229,784)63,121 (78,191)(284,571)(11,990)(42,417)
Accumulated deferred income taxes and taxes accrued($1,286,123)($2,138,522)($646,674)($338,714)($639,422)($359,835)
The Registrant Subsidiaries’ estimated tax attributes carryovers and their expiration dates as of December 31, 2021 are as follows:

 Entergy ArkansasEntergy LouisianaEntergy MississippiEntergy New OrleansEntergy TexasSystem Energy
       
Federal net operating losses before 1/1/2018$— billion$1.7 billion$— billion$0.9 billion$— billion$— billion
Year(s) of expirationN/A2035-2037N/A2037N/AN/A
Federal net operating losses - 1/1/2018 forward$4.5 billion$4.5 billion$2.1 billion$0.7 billion$2.6 billion$— billion
Year(s) of expirationN/AN/AN/AN/AN/AN/A
       
State net operating losses$4.8 billion$7.2 billion$2.3 billion$1.7 billion$— million$— million
Year(s) of expiration2023-2026N/A2038-2041N/AN/AN/A
       
Misc. federal credits$4.7 million$12.3 million$1.8 million$15.3 million$3.1 million$1.5 million
Year(s) of expiration2038-20412035-20412038-20412037-20412036-20412036-2041
       
State credits$— million$— million$1.3 million$—million$2.9 million$9 million
Year(s) of expirationN/AN/A2022-2025N/A20272022-2025

As a result of the accounting for uncertain tax positions, the amount of the deferred tax assets reflected in the financial statements is less than the amount of the tax effect of the federal and state net operating loss carryovers and tax credit carryovers.

Unrecognized tax benefits

Accounting standards establish a “more-likely-than-not” recognition threshold that must be met before a tax benefit can be recognized in the financial statements.  If a tax deduction is taken on a tax return but does not meet the more-likely-than-not recognition threshold, an increase in income tax liability, above what is payable on the tax return, is required to be recorded.  A reconciliation of Entergy’s beginning and ending amount of unrecognized tax benefits is as follows:
 202120202019
 (In Thousands)
Gross balance at January 1$5,699,339 $7,383,154 $7,181,482 
Additions based on tax positions related to the current year101,623 669,207 731,276 
Additions for tax positions of prior years33,419 98,591 151,628 
Reductions for tax positions of prior years (74,413)(935,735)(681,232)
Settlements— (1,515,878)— 
Gross balance at December 315,759,968 5,699,339 7,383,154 
Offsets to gross unrecognized tax benefits:   
Loss and tax credit carryovers(4,987,799)(4,710,214)(5,831,587)
Cash paid to taxing authorities(60,000)(10,000)(10,000)
Unrecognized tax benefits net of unused tax attributes, refund claims and payments (a)$712,169 $979,125 $1,541,567 
(a)Potential tax liability above what is payable on tax returns

The balances of unrecognized tax benefits include $2,256 million, $2,208 million, and $2,421 million as of December 31, 2021, 2020, and 2019, respectively, which, if recognized, would lower the effective income tax rates.  Because of the effect of deferred tax accounting, the remaining balances of unrecognized tax benefits of $3,504 million, $3,491 million, and $4,962 million as of December 31, 2021, 2020, and 2019, respectively, if disallowed, would not affect the annual effective income tax rate but would accelerate the payment of cash to the taxing authority to an earlier period.

Entergy accrues interest expense, if any, related to unrecognized tax benefits in income tax expense.  Entergy’s December 31, 2021, 2020, and 2019 accrued balance for the possible payment of interest is approximately $52 million, $44 million, and $48 million, respectively. Interest (net-of-tax) of $8 million, ($4) million, and $4 million was recorded in 2021, 2020, and 2019, respectively.

A reconciliation of the Registrant Subsidiaries’ beginning and ending amount of unrecognized tax benefits for 2021, 2020, and 2019 is as follows:
2021Entergy ArkansasEntergy LouisianaEntergy MississippiEntergy New OrleansEntergy TexasSystem Energy
 (In Thousands)
Gross balance at January 1, 2021$1,364,635 $640,295 $549,717 $639,546 $521,932 $21,652 
Additions based on tax positions related to the current year30,419 13,437 684 1,050 32,616 1,753 
Additions for tax positions of prior years15,013 9,304 1,504 2,315 1,897 
Reductions for tax positions of prior years(1,573)(58,408)(2,336)(1,105)(4,568)(1,946)
Gross balance at December 31, 20211,408,494 604,628 549,569 639,497 552,295 23,356 
Offsets to gross unrecognized tax benefits:      
Loss and tax credit carryovers(992,643)(604,628)(388,728)(484,899)(540,694)(8,576)
Unrecognized tax benefits net of unused tax attributes and payments$415,851 $— $160,841 $154,598 $11,601 $14,780 

2020Entergy ArkansasEntergy LouisianaEntergy MississippiEntergy New OrleansEntergy TexasSystem Energy
 (In Thousands)
Gross balance at January 1, 2020$1,341,242 $2,381,653 $566,287 $716,773 $21,406 $473,331 
Additions based on tax positions related to the current year (a)9,403 35,681 5,619 2,430 504,362 4,013 
Additions for tax positions of prior years13,400 10,508 1,156 294 799 4,606 
Reductions for tax positions of prior years(11,346)(679,601)(24,173)(80,267)(5,559)(41,466)
Settlements11,936 (1,107,946)828 316 924 (418,832)
Gross balance at December 31, 20201,364,635 640,295 549,717 639,546 521,932 21,652 
Offsets to gross unrecognized tax benefits:      
Loss and tax credit carryovers(1,112,628)(640,295)(465,679)(451,922)(507,720)(7,413)
Unrecognized tax benefits net of unused tax attributes and payments$252,007 $— $84,038 $187,624 $14,212 $14,239 
2019Entergy ArkansasEntergy LouisianaEntergy MississippiEntergy New OrleansEntergy TexasSystem Energy
 (In Thousands)
Gross balance at January 1, 2019$1,298,662 $2,400,171 $508,765 $686,687 $17,802 $467,487 
Additions based on tax positions related to the current year84,335 28,705 68,594 40,676 2,312 5,496 
Additions for tax positions of prior years20,399 25,090 1,651 489 1,299 2,186 
Reductions for tax positions of prior years(62,154)(72,313)(12,723)(11,079)(7)(1,838)
Gross balance at December 31, 20191,341,242 2,381,653 566,287 716,773 21,406 473,331 
Offsets to gross unrecognized tax benefits:      
Loss and tax credit carryovers(1,134,187)(1,573,257)(506,976)(445,430)(3,944)(8,392)
Unrecognized tax benefits net of unused tax attributes and payments$207,055 $808,396 $59,311 $271,343 $17,462 $464,939 

(a)The primary additions for Entergy Texas in 2020 are related to the mark-to-market treatment discussed in “Other Tax Matters - Tax Accounting Methods” below.

The Registrant Subsidiaries’ balances of unrecognized tax benefits included amounts which, if recognized, would have reduced income tax expense as follows:
December 31,
 202120202019
 (In Millions)
Entergy Arkansas$262.1 $259.3 $203.3 
Entergy Louisiana$66.3 $63.8 $556.3 
Entergy Mississippi$51.7 $50.7 $1.9 
Entergy New Orleans$228.6 $203.5 $242.7 
Entergy Texas$2.6 $6.1 $5.7 
System Energy$1.7 $0.5 $— 

Accrued balances for the possible payment of interest related to unrecognized tax benefits are as follows:
December 31,
 202120202019
 (In Millions)
Entergy Arkansas$2.7 $2.3 $3.1 
Entergy Louisiana$3.7 $3.4 $14.2 
Entergy Mississippi$2.4 $1.9 $1.7 
Entergy New Orleans$5.2 $3.9 $4.7 
Entergy Texas$1.1 $0.9 $1.1 
System Energy$12.1 $11.9 $14.5 
The Registrant Subsidiaries record interest and penalties related to unrecognized tax benefits in income tax expense.  No penalties were recorded in 2021, 2020, and 2019. Interest (net-of-tax) was recorded as follows:
202120202019
(In Millions)
Entergy Arkansas$0.4 ($0.8)$1.4 
Entergy Louisiana$0.3 ($10.8)($3.7)
Entergy Mississippi$0.5 $0.2 $0.5 
Entergy New Orleans$1.3 ($0.8)$2.0 
Entergy Texas$0.2 ($0.2)$0.2 
System Energy$0.2 ($2.6)$1.3 

Income Tax Audits

Entergy and its subsidiaries file U.S. federal and various state income tax returns.  IRS examinations are complete for years before 2016. All state taxing authorities’ examinations are complete for years before 2014. Entergy regularly defends its positions and works with the IRS to resolve audits.  The resolution of audit issues could result in significant changes to the amounts of unrecognized tax benefits in the next twelve months.

2014-2015 IRS Audit

The IRS completed its examination of the 2014 and 2015 tax years and issued its 2014-2015 RAR in November 2020. Entergy agreed to all proposed adjustments contained in the RAR. Entergy and the Registrant Subsidiaries recorded the effects of the adjustments associated with the audit in 2020.

In October 2015 two of Entergy’s Louisiana utilities, Entergy Gulf States Louisiana and Entergy Louisiana, combined their businesses into a legal entity which is identified as Entergy Louisiana herein. The structure of the business combination required Entergy to recognize a gain for income tax purposes which resulted in an increase in the tax basis of the assets for Entergy Louisiana. This resulted in recognition in 2015 of a $334 million permanent difference and income tax benefit, net of the uncertain tax position recorded on the transaction.

Primarily related to resolution of the business combination issues, completion of the 2014-2015 IRS audit in 2020 resulted in a $230 million reduction to deferred income tax expense for Entergy. This reduction to deferred income tax expense includes: Entergy Louisiana reversing its provision for uncertain tax position with respect to the business combination, which resulted in a reduction to deferred income tax expense of $383 million; Entergy Corporation recording an increase to deferred tax expense of $61 million and Entergy Wholesale Commodities recording an increase to deferred tax expense of $105 million from the re-measurement of deferred tax assets associated with the resolved uncertain tax position; and miscellaneous other individually insignificant benefits totaling $13 million.

The completion of the 2014-2015 tax audit also resulted in a $31 million reduction to income tax expense associated with Entergy Louisiana’s method of accounting related to the adoption of tangible property regulations. As a result of the settlement of the tangible property regulation tax position, Entergy Louisiana was required to record a $33 million ($24 million net-of-tax) regulatory charge and a corresponding regulatory liability to reflect its obligation to customers pursuant to a prior regulatory settlement.

Finally, upon completion of the 2014-2015 tax audit, Entergy New Orleans recorded a reduction to income tax expense of $8 million associated with claims for mark-to-market deductions.

In the first quarter 2020, Entergy and the IRS agreed on the treatment of funds received by Entergy Louisiana in conjunction with the Act 55 financing of Hurricane Isaac storm costs, which resulted in a net reduction
of income tax expense of approximately $32 million. As a result of the settlement, the position was partially sustained, and Entergy Louisiana recorded a reduction of income tax expense of approximately $58 million primarily due to the reversal of a provision for uncertain tax positions in excess of the agreed-upon settlement. As a result of the IRS settlement, Entergy Louisiana recorded a $29 million ($21 million net-of-tax) regulatory charge and a corresponding regulatory liability to reflect its obligation to customers pursuant to the LPSC Hurricane Isaac Act 55 financing order.

Additional effects of the completion of the 2014-2015 IRS tax audit are discussed below within Tax Accounting Methods.

Other Tax Matters

Tax Cuts and Jobs Act (TCJA)

The most significant effect of the TCJA for Entergy and the Registrant Subsidiaries was the change in the federal corporate income tax rate from 35% to 21%, effective January 1, 2018.

TCJA also limited the deduction for net business interest expense to 30 percent of adjusted taxable income, which is similar to earnings before interest, taxes, depreciation, and amortization. The limitation does not apply to interest expense that is properly allocable to a trade or business classified as a regulated public utility. This was further modified by a temporary provision of the CARES Act resulting in an increase of the adjusted taxable income limitation from 30% to 50% for tax years that begin in 2019 or 2020.

The IRS issued final regulations which are effective for Entergy beginning with the 2021 tax year. The regulations provide that if 90% of a tax group’s consolidated assets consist of regulated utility property, the entire consolidated tax group will be treated as a regulated public utility and all of the consolidated group’s interest expense will be currently tax deductible. Entergy expects that this provision will continue to apply to Entergy’s business operations making the application of this limitation to Entergy less likely. The provision has not resulted in Entergy having to report any significant business interest expense limitations on its tax returns.

With respect to the federal corporate income tax rate change from 35% to 21% in 2017, Entergy and the Registrant Subsidiaries recorded a regulatory liability associated with the decrease in the net accumulated deferred income tax liability, which is often referred to as “excess ADIT,” a significant portion of which has been paid to customers in 2019, 2020 and 2021 in the form of lower rates. Entergy’s December 31, 2021 and December 31, 2020 balance sheets reflect a regulatory liability of $1.3 billion and $1.6 billion, respectively, as a result of the re-measurement of deferred tax assets and liabilities from the income tax rate change, amortization of excess ADIT, and payments to customers during 2019, 2020 and 2021. Entergy’s regulatory liability for income taxes includes a gross-up at the applicable tax rate because of the effect that excess ADIT has on the ratemaking formula. The regulatory liability for income taxes includes the effect of a) the reduction of the net deferred tax liability resulting in excess ADIT, and b) the tax gross-up of excess ADIT. The Registrant Subsidiaries’ December 31, 2021 and December 31, 2020 balance sheets reflect net regulatory liabilities for income taxes as follows:
20212020
(In Millions)
Entergy Arkansas$432 $467 
Entergy Louisiana$338 $479 
Entergy Mississippi$212 $224 
Entergy New Orleans$42 $59 
Entergy Texas$171 $205 
System Energy$113 $152 
Excess ADIT is generally classified into two categories: 1) the portion that is subject to the normalization requirements of the TCJA, i.e., “protected”, and 2) the portion that is not subject to such normalization provisions, referred to as “unprotected”. The TCJA provides that the normalization method of accounting for income taxes is required for excess ADIT associated with public utility property. The TCJA provides for the use of the average rate assumption method (ARAM) for the determination of the timing of the return of excess ADIT associated with such property. Under ARAM, the excess ADIT is reduced over the remaining life of the asset. Remaining asset lives vary for each Registrant Subsidiary, but the average life of public utility property is typically 30 years or longer. Entergy will amortize the protected portion of the excess ADIT in conformity with the normalization requirements. The Registrant Subsidiaries’ net regulatory liability for income taxes as of December 31, 2021 and December 31, 2020, includes protected excess ADIT as follows:
20212020
(In Millions)
Entergy Arkansas$463 $490 
Entergy Louisiana$669 $721 
Entergy Mississippi$237 $248 
Entergy New Orleans$56 $61 
Entergy Texas$208 $215 
System Energy$148 $173 

Payment of the unprotected excess accumulated deferred income taxes results in a reduction in the regulatory liability for income taxes and a corresponding reduction in income tax expense. This has a significant effect on the effective tax rate for the period as compared to the statutory tax rate. The Registrant Subsidiaries’ net regulatory liability for income taxes as of December 31, 2021 and December 31, 2020, includes unprotected excess ADIT as follows:
20212020
(In Millions)
Entergy Arkansas$12 $11 
Entergy Louisiana$148 $223 
Entergy New Orleans$— $3 
Entergy Texas$26 $54 
System Energy$— $16 

The return of unprotected excess accumulated deferred income taxes reduced Entergy’s and the Registrant Subsidiaries’ regulatory liability for income taxes as follows for 2021 and 2020:
20212020
(In Millions)
Entergy$88 $74 
Entergy Arkansas$8 $8 
Entergy Louisiana$33 $31 
Entergy New Orleans$1 $6 
Entergy Texas$28 $29 
System Energy$18 $— 

In addition to the protected and unprotected excess ADIT amounts, the net regulatory liability for income taxes includes other regulatory assets and liabilities for income taxes associated with AFUDC, which is described in Note 1 to the financial statements.
Included in the effect of the computation of the changes in deferred tax assets and liabilities is the recognition threshold and measurement of uncertain tax positions resulting in unrecognized tax benefits. The final economic outcome of such unrecognized tax benefits is generally the result of a negotiated settlement with the IRS that often differs from the amount that is recorded as realizable under GAAP. The intrinsic uncertainty with respect to all such tax positions means that the difference between current estimates of such amounts likely to be realized and actual amounts realized upon settlement may have an effect on income tax expense and the regulatory liability for income taxes in future periods.

Entergy anticipates that the effect of TCJA may continue to have ramifications that require adjustments in the future as certain events occur. These events include: 1) IRS audit adjustments to or amendments of federal and state income tax returns that include modifications to the computation of taxable income resulting from TCJA; and 2) additional guidance, interpretations, or rulings by the U.S. Department of the Treasury or the IRS. The potential exists for these types of events to result in future tax expense adjustments because of the difference in the federal corporate income tax rate between past and future periods and the effect of the tax rate change on ratemaking. In turn, these events also could potentially affect the regulatory liability for income taxes.

Coronavirus Aid, Relief, and Economic Security Act

In response to the economic impacts of the COVID-19 pandemic, President Trump signed the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) into law on March 27, 2020. The CARES Act provisions that result in the most significant opportunities for tax relief to Entergy and the Registrant Subsidiaries are (i) permitting a five-year carryback of 2018-2020 NOLs, (ii) removing the 80 percent limitation on NOLs carried to tax years beginning before 2021, (iii) increasing the limitation on interest expense deductibility for 2019 and 2020, (iv) accelerating available refunds for minimum tax credit carryforwards, modifying limitations on charitable contributions during 2020, and (v) delaying the payment of employer payroll taxes. Entergy deferred approximately $64 million of 2020 payroll tax payments, payable in equal installments over two years. The initial installment of $32 million was paid in December 2021. The second installment will be paid in December 2022.

Entergy Wholesale Commodities Restructuring

In the fourth quarter 2019, two separate events occurred resulting in a reduction of tax expense of $174 million. In November 2019 an Entergy Wholesale Commodities subsidiary recognized a reduction in income tax expense of $18 million in connection with the accounting method on power contracts associated with the Palisades nuclear power station. Additionally, Entergy’s ownership of Indian Point 2 and Indian Point 3 was restructured. The restructuring required Entergy to recognize Indian Point 2 and Indian Point 3 nuclear decommissioning liabilities for income tax purposes resulting in a tax accounting permanent difference that reduced income tax expense, net of unrecognized tax benefits, by $156 million. The accrual of the nuclear decommissioning liabilities also required Entergy to recognize a gain for income tax purposes, a portion of which resulted in an increase in the tax basis of the assets. Recognition of the gain and the increase in the tax basis of the assets represents a tax accounting temporary difference.

Immediately prior to the restructuring, through its ownership of Indian Point 2 and Indian Point 3, Entergy donated property to Stony Brook University and recognized an associated tax deduction resulting in a decrease to tax expense of $19 million.

In the fourth quarter 2020, Entergy’s ownership of Palisades was restructured. The restructuring required Entergy to recognize Palisades’ nuclear decommissioning liability for income tax purposes resulting in a tax accounting permanent difference that reduced income tax expense, net of unrecognized tax benefits, by $9.2 million. The accrual of the nuclear decommissioning liability also required Entergy to recognize a gain for income tax purposes, a portion of which resulted in an increase in the tax basis of the assets. Recognition of the gain and the increase in the tax basis of the assets represents a tax accounting temporary difference.
Tax Accounting Methods

In the fourth quarter 2015, System Energy and Entergy Louisiana adopted a new method of accounting for income tax return purposes in which their nuclear decommissioning costs will be treated as production costs of electricity includable in cost of goods sold. The new method resulted in a reduction of taxable income of $1.2 billion for System Energy and $2.2 billion for Energy Louisiana.

In conjunction with the 2014-2015 IRS audit discussed above, the IRS issued proposed adjustments concerning the nuclear decommissioning tax position allowing System Energy to include $102 million of its decommissioning liability in cost of goods sold, and Entergy Louisiana to include $221 million of its decommissioning liability in cost of goods sold. Entergy, System Energy, and Entergy Louisiana agreed to the proposed adjustments included in the RAR.

As a result of System Energy being allowed to include part of its decommissioning liability in cost of goods sold, System Energy and Entergy recorded a deferred tax liability of $26 million. System Energy also recorded federal and state taxes payable of $402 million. However, on a consolidated basis, Entergy utilized tax loss carryovers to offset the federal taxable income adjustment and did not record federal taxes payable as a result of the outcome of this uncertain tax position.

As a result of Entergy Louisiana being allowed to include part of its decommissioning liability in cost of goods sold, Entergy Louisiana and Entergy recorded a deferred tax liability of $60 million. Both Entergy Louisiana and Entergy utilized tax loss carryovers to offset the taxable income adjustment and accordingly did not record taxes payable as a result of the outcome of this uncertain tax position.

The partial disallowance of this uncertain tax position to include the decommissioning liability in cost of goods sold resulted in a $1.5 billion decrease in the balance of unrecognized tax benefits related to federal and state taxes for Entergy. Additionally, both System Energy and Entergy Louisiana recorded a reduction to their balances of unrecognized tax benefits for federal and state taxes of $461 million and $1.1 billion, respectively.

Entergy Arkansas adopted the same method of accounting for its nuclear decommissioning costs which resulted in a $1.8 billion reduction in taxable income on its 2018 tax return.

In 2016, Entergy Louisiana elected mark-to-market income tax treatment for various wholesale electric power purchase and sale agreements, including Entergy Louisiana’s contract to purchase electricity from the Vidalia hydroelectric facility and from System Energy under the Unit Power Sales Agreement. The election resulted in a $2.2 billion deductible temporary difference. In 2017, Entergy New Orleans also elected mark-to-market income tax treatment for wholesale electric contracts which resulted in a $1.1 billion deductible temporary difference. In 2018, Entergy Arkansas and Entergy Mississippi accrued deductible temporary differences related to mark-to-market tax accounting for wholesale electric contracts of $2.1 billion and $1.9 billion, respectively. Additionally, in 2020, Entergy Texas elected mark-to-market income tax treatment for wholesale electric power purchase and sale agreements which resulted in a $2.5 billion deductible temporary difference.

Arkansas and Louisiana Corporate Income Tax Rate Changes

In April 2019 and December 2021 the State of Arkansas enacted corporate income tax law changes that phased in rate reductions from the former rate of 6.5% to 6.2% in 2021, 5.9% in 2022, and 5.7% in 2023.    As a result of the 2019 rate reduction, Entergy Arkansas computed a regulatory liability for income taxes as of December 31, 2020 of approximately $21 million, which includes a tax gross-up related to the treatment of income taxes in the retail and wholesale ratemaking formulas and has been included in the appropriate rate mechanisms. Entergy Arkansas recorded an incremental regulatory liability of $11 million associated with the rate reduction enacted in December 2021. The Arkansas tax law enactment also phases in an increase to the net operating loss carryover period from five to ten years.
Pursuant to legislation enacted in 2021 and approved by Louisiana citizens by amendment to the state constitution, beginning January 1, 2022, federal income taxes paid will no longer be deductible for state income tax purposes, and the top Louisiana corporate income tax rate will be reduced from 8% to 7.5%. As a result of this change in Louisiana tax law, the Louisiana applicable tax rate increased by 0.85%. Accordingly, deferred tax assets and liabilities were adjusted to reflect the new applicable federal and state rates. Legislation enacted in 2021 also provides that Louisiana net operating losses generally have an indefinite carryover period.

Entergy recorded a net increase to its deferred tax asset of $27 million. Entergy Louisiana and Entergy New Orleans recorded net increases to their deferred tax liabilities before consideration of the tax gross-up of $77 million and $8 million, respectively, which were offset by regulatory assets for income taxes. Therefore, these increases had no effect on tax expense. However, the increase of deferred tax assets associated with certain assets reduced tax expense for Entergy Louisiana and Entergy New Orleans by $6 million and $2 million, respectively.

Consolidated Income Tax Return of Entergy Corporation

In September 2019, Entergy Utility Holding Company, LLC and its regulated, wholly-owned subsidiaries including Entergy Arkansas, Entergy Louisiana, Entergy Mississippi, and Entergy New Orleans, became eligible to and joined the Entergy Corporation consolidated federal income tax group.  As a result of these four Utility operating companies re-joining the Entergy Corporation consolidated tax return group, Entergy was able to recognize a $41 million deferred tax asset associated with a previously unrecognized net operating loss carryover.

In September 2019, Entergy Texas issued $35 million of 5.375% Series A preferred stock with a liquidation value of $25 per share resulting in the disaffiliation and de-consolidation of Entergy Texas from the consolidated federal income tax return of Entergy Corporation.  These changes will not affect the accrual or allocation of income taxes for the Registrant Subsidiaries. See Note 6 to the financial statements for discussion of the preferred stock issuance.

Vermont Yankee

The Vermont Yankee transaction resulted in Entergy generating a net deferred tax asset in January 2019.  The deferred tax asset could not be fully realized by Entergy in the first quarter 2019; accordingly, Entergy accrued a net tax expense of $29 million on the disposition of Vermont Yankee. See Note 14 to the financial statements for discussion of the Vermont Yankee transaction.

Stock Compensation

In accordance with stock compensation accounting rules, Entergy and the Registrant Subsidiaries recognized excess tax deductions as a reduction of income tax expense in the first quarter 2020. Due to the vesting and exercise of certain Entergy stock-based awards, Entergy recorded a permanent tax reduction of approximately $24.7 million, including $4.8 million for Entergy Arkansas, $8.6 million for Entergy Louisiana, $2.7 million for Entergy Mississippi, $1.5 million for Entergy New Orleans, $2.7 million for Entergy Texas, and $1.3 million for System Energy.
Entergy Mississippi [Member]  
Income Taxes INCOME TAXES (Entergy Corporation, Entergy Arkansas, Entergy Louisiana, Entergy Mississippi, Entergy New Orleans, Entergy Texas, and System Energy)
Income taxes for 2021, 2020, and 2019 for Entergy Corporation and Subsidiaries consist of the following:
 202120202019
 (In Thousands)
Current:   
Federal($5,003)$5,807 ($14,416)
State(8,995)57,939 6,535 
Total(13,998)63,746 (7,881)
Deferred and non-current - net205,891 (190,635)(155,956)
Investment tax credit adjustments - net(519)5,383 (5,988)
Income taxes$191,374 ($121,506)($169,825)

Income taxes for 2021, 2020, and 2019 for Entergy’s Registrant Subsidiaries consist of the following:
2021Entergy ArkansasEntergy LouisianaEntergy MississippiEntergy New OrleansEntergy TexasSystem Energy
(In Thousands)
Current:      
Federal($20,285)($24,053)($5,868)($6,724)($189)$29,416 
State529 2,459 (11,506)(413)1,261 (10,258)
Total(19,756)(21,594)(17,374)(7,137)1,072 19,158 
Deferred and non-current - net96,180 146,786 60,861 12,870 25,087 (25,229)
Investment tax credit adjustments - net(1,229)(4,783)1,836 203 (633)4,094 
Income taxes$75,195 $120,409 $45,323 $5,936 $25,526 ($1,977)

2020Entergy ArkansasEntergy LouisianaEntergy MississippiEntergy New OrleansEntergy TexasSystem Energy
 (In Thousands)
Current:      
Federal($44,627)$62,728 ($14,580)$293 ($5,603)$372,206 
State(2,563)4,457 (1,316)(303)2,658 55,551 
Total(47,190)67,185 (15,896)(10)(2,945)427,757 
Deferred and non-current - net96,195 (444,647)43,640 (18,153)6,619 (405,928)
Investment tax credit adjustments - net(1,228)(4,862)(554)13,956 (632)(1,286)
Income taxes$47,777 ($382,324)$27,190 ($4,207)$3,042 $20,543 
2019Entergy ArkansasEntergy LouisianaEntergy MississippiEntergy New OrleansEntergy TexasSystem Energy
 (In Thousands)
Current:      
Federal($14,549)($20,173)($8,939)($5,822)$16,035 $16,256 
State(714)(735)5,823 1,856 663 (2,831)
Total(15,263)(20,908)(3,116)(3,966)16,698 13,425 
Deferred and non-current - net(30,278)147,453 34,579 4,248 (69,963)422 
Investment tax credit adjustments - net(1,228)(4,922)(597)(96)(631)1,502 
Income taxes($46,769)$121,623 $30,866 $186 ($53,896)$15,349 

Total income taxes for Entergy Corporation and Subsidiaries differ from the amounts computed by applying the statutory income tax rate to income before income taxes.  The reasons for the differences for the years 2021, 2020, and 2019 are:
 202120202019
 (In Thousands)
Net income attributable to Entergy Corporation$1,118,492 $1,388,334 $1,241,226 
Preferred dividend requirements of subsidiaries227 18,319 17,018 
Consolidated net income1,118,719 1,406,653 1,258,244 
Income taxes191,374 (121,506)(169,825)
Income before income taxes$1,310,093 $1,285,147 $1,088,419 
Computed at statutory rate (21%)$275,120 $269,881 $228,568 
Increases (reductions) in tax resulting from:   
State income taxes net of federal income tax effect79,273 60,087 61,791 
Regulatory differences - utility plant items(57,556)(53,229)(45,336)
Equity component of AFUDC(14,799)(25,080)(30,444)
Amortization of investment tax credits(7,695)(8,386)(8,093)
Flow-through / permanent differences(5,585)11,099 (2,059)
Amortization of excess ADIT (a)(66,478)(59,629)(205,614)
Arkansas and Louisiana Rate Changes (b)(27,108)— — 
IRS audit adjustment (d)— (301,041)— 
Entergy Wholesale Commodities restructuring (c)— (9,223)(173,725)
Stock compensation (e)— (25,591)— 
Charitable contribution (c)— — (19,101)
Net operating loss recognition— — (41,427)
Provision for uncertain tax positions16,533 15,208 7,332 
Valuation allowance(2,600)— 59,345 
Other - net2,269 4,398 (1,062)
Total income taxes as reported$191,374 ($121,506)($169,825)
Effective Income Tax Rate14.6 %(9.5 %)(15.6 %)

(a)See “Other Tax Matters - Tax Cuts and Jobs Act” below for discussion of the amortization of excess accumulated deferred income taxes (ADIT) in 2019, 2020, and 2021 and the tax legislation enactment in 2017.
(b)See “Arkansas and Louisiana Corporate Income Tax Rate Changes” below for details.
(c)See Other Tax Matters - Entergy Wholesale Commodities Restructuring” below for discussion of the Entergy Wholesale Commodities restructuring in 2019, the ownership of Palisades restructuring in 2020, and the charitable contribution in 2019.
(d)See “Income Tax Audits - 2014-2015 IRS Audit” below for discussion of the resolution of the audit in 2020.
(e)See “Other Tax Matters - Stock Compensation” below for discussion of excess tax deductions.

Total income taxes for the Registrant Subsidiaries differ from the amounts computed by applying the statutory income tax rate to income before taxes.  The reasons for the differences for the years 2021, 2020, and 2019 are:
2021Entergy ArkansasEntergy LouisianaEntergy MississippiEntergy New OrleansEntergy TexasSystem Energy
 (In Thousands)
Net income$298,484 $653,984 $166,834 $31,798 $228,824 $106,814 
Income taxes75,195 120,409 45,323 5,936 25,526 (1,977)
Pretax income$373,679 $774,393 $212,157 $37,734 $254,350 $104,837 
Computed at statutory rate (21%)$78,473 $162,623 $44,553 $7,924 $53,413 $22,016 
Increases (reductions) in tax resulting from:     
State income taxes net of federal income tax effect19,633 41,030 9,305 2,579 1,553 5,385 
Regulatory differences - utility plant items(16,078)(14,123)(8,133)(4,332)(2,115)(12,776)
Equity component of AFUDC(3,207)(6,016)(1,701)(498)(2,077)(1,300)
Amortization of investment tax credits(1,201)(4,729)64 (56)(617)(1,155)
Flow-through / permanent differences(814)(2,655)124 1,559 (475)(1,235)
Amortization of excess ADIT (a)(5,845)(24,323)— (1,028)(21,929)(13,354)
Arkansas and Louisiana Rate Changes (b)398 (6,126)395 (1,569)216 115 
Non-taxable dividend income— (26,801)— — — — 
Provision for uncertain tax positions353 300 465 1,200 (2,716)200 
Valuation Allowance2,766 — — — — — 
Other - net717 1,229 251 157 273 127 
Total income taxes as reported$75,195 $120,409 $45,323 $5,936 $25,526 ($1,977)
Effective Income Tax Rate20.1 %15.5 %21.4 %15.7 %10.0 %(1.9 %)
2020Entergy ArkansasEntergy LouisianaEntergy MississippiEntergy New OrleansEntergy TexasSystem Energy
 (In Thousands)
Net income$245,232 $1,082,352 $140,583 $49,338 $215,073 $99,131 
Income taxes47,777 (382,324)27,190 (4,207)3,042 20,543 
Pretax income$293,009 $700,028 $167,773 $45,131 $218,115 $119,674 
Computed at statutory rate (21%)$61,532 $147,006 $35,232 $9,478 $45,804 $25,132 
Increases (reductions) in tax resulting from:
State income taxes net of federal income tax effect16,256 38,182 6,917 2,606 1,460 5,524 
Regulatory differences - utility plant items(8,034)(23,819)(7,441)(3,442)(7,673)(2,821)
Equity component of AFUDC(3,154)(8,012)(1,412)(1,331)(9,255)(1,916)
Amortization of investment tax credits(1,201)(4,811)(540)(61)(617)(1,155)
Flow-through / permanent differences(2,219)1,404 (102)498 766 (421)
Amortization of excess ADIT (a)(6,011)(26,293)18 (4,564)(22,780)— 
Stock compensation (d)(4,952)(9,004)(2,763)(1,526)(2,842)(1,300)
IRS audit adjustment (c)(6,351)(471,702)(3,768)(6,819)(2,091)(2,925)
Non-taxable dividend income— (26,795)— — — — 
Provision for uncertain tax positions1,200 300 800 800 — 300 
Other - net711 1,220 249 154 270 125 
Total income taxes as reported$47,777 ($382,324)$27,190 ($4,207)$3,042 $20,543 
Effective Income Tax Rate16.3 %(54.6 %)16.2 %(9.3 %)1.4 %17.2 %

2019Entergy ArkansasEntergy LouisianaEntergy MississippiEntergy New OrleansEntergy TexasSystem Energy
 (In Thousands)
Net income$262,964 $691,537 $119,925 $52,629 $159,397 $99,120 
Income taxes(46,769)121,623 30,866 186 (53,896)15,349 
Pretax income$216,195 $813,160 $150,791 $52,815 $105,501 $114,469 
Computed at statutory rate (21%)$45,401 $170,764 $31,666 $11,091 $22,155 $24,039 
Increases (reductions) in tax resulting from:      
State income taxes net of federal income tax effect15,954 42,854 5,563 3,443 360 5,134 
Regulatory differences - utility plant items(10,627)(19,421)(5,556)(1,532)(1,987)(6,213)
Equity component of AFUDC(3,255)(15,545)(1,755)(2,088)(5,973)(1,829)
Amortization of investment tax credits(1,201)(4,871)(160)(88)(617)(1,155)
Flow-through / permanent differences696 439 160 (741)560 (500)
Amortization of excess ADIT (a)(90,921)(28,531)203 (11,724)(69,091)(5,550)
Non-taxable dividend income— (26,795)— — — — 
Provision for uncertain tax positions(3,517)1,519 500 1,672 430 1,300 
Other - net701 1,210 245 153 267 123 
Total income taxes as reported($46,769)$121,623 $30,866 $186 ($53,896)$15,349 
Effective Income Tax Rate(21.6 %)15.0 %20.5 %0.4 %(51.1 %)13.4 %
(a)See “Other Tax Matters - Tax Cuts and Jobs Act” below for discussion of the amortization of excess accumulated deferred income taxes (ADIT) in 2019, 2020 and 2021 and the tax legislation enactment in 2017.
(b)See “Arkansas and Louisiana Corporate Income Tax Rate Changes” below for details.
(c)See “Income Tax Audits - 2014-2015 IRS Audit” below for discussion of the resolution of the audit in 2020.
(d)See “Other Tax Matters - Stock Compensation” below for discussion of excess tax deductions.


Significant components of accumulated deferred income taxes and taxes accrued for Entergy Corporation and Subsidiaries as of December 31, 2021 and 2020 are as follows:
 
 20212020
 (In Thousands)
Deferred tax liabilities:  
Plant basis differences - net($6,136,563)($4,795,422)
Regulatory assets(930,244)(429,996)
Nuclear decommissioning trusts/receivables(656,185)(1,188,235)
Pension, net regulatory asset(322,788)(327,445)
Combined unitary state taxes(7,255)(7,723)
Unbilled/deferred revenues— (9,152)
Accumulated storm damage provision(207,243)— 
Deferred fuel(85,310)(7,667)
Other(341,450)(549,355)
Total(8,687,038)(7,314,995)
Deferred tax assets:  
Nuclear decommissioning liabilities278,136 968,464 
Regulatory liabilities1,318,381 791,927 
Pension and other post-employment benefits208,128 278,486 
Sale and leaseback102,474 102,477 
Compensation79,798 89,279 
Accumulated deferred investment tax credit57,986 57,379 
Provision for allowances and contingencies82,286 71,598 
Power purchase agreements55,259 352,019 
Unbilled/deferred revenues26,683 — 
Net operating loss carryforwards2,868,424 1,580,109 
Capital losses and miscellaneous tax credits11,111 21,291 
Valuation allowance(325,239)(328,581)
Other200,032 230,291 
Total4,963,459 4,214,739 
Non-current accrued taxes (including unrecognized tax benefits)(929,032)(1,185,227)
Accumulated deferred income taxes and taxes accrued($4,652,611)($4,285,483)
Entergy’s estimated tax attributes carryovers and their expiration dates as of December 31, 2021 are as follows:
Carryover DescriptionCarryover AmountYear(s) of expiration
   
Federal net operating losses before 1/1/2018$6.2 billion2023-2027
Federal net operating losses - 1/1/2018 forward$21.1 billionN/A
State net operating losses$7.4 billion2022-2041
State net operating losses with no expiration$16.7 billionN/A
Federal and state charitable contributions$460.8 million2022-2026
Miscellaneous federal and state credits$73.1 million2022-2041

As a result of the accounting for uncertain tax positions, the amount of the deferred tax assets reflected in the financial statements is less than the amount of the tax effect of the federal and state net operating loss carryovers, tax credit carryovers, and other tax attributes reflected on income tax returns. Entergy evaluates the available positive and negative evidence to estimate whether sufficient future taxable income of the appropriate character will be generated to realize the benefits of existing deferred tax assets. When the evaluation indicates that Entergy will not be able to realize the existing benefits, a valuation allowance is recorded to reduce deferred tax assets to the realizable amount.

Because it is more likely than not that the benefits from certain state net operating losses and other deferred tax assets will not be utilized, valuation allowances totaling $325 million as of December 31, 2021 and $329 million as of December 31, 2020 have been provided on the deferred tax assets related to federal and state jurisdictions in which Entergy does not currently expect to be able to utilize certain separate company tax return attributes, preventing realization of such deferred tax assets. As a result of incurring costs related to Hurricane Ida restoration, certain Utility operating companies are entitled to an accelerated tax deduction which generated a taxable loss in various taxing jurisdictions. This accelerated deduction has impaired the realizability of a limited term carryover tax attribute. Accordingly, the impairment contributed to the activity reflected for the valuation allowance disclosed above.
Significant components of accumulated deferred income taxes and taxes accrued for the Registrant Subsidiaries as of December 31, 2021 and 2020 are as follows:
2021Entergy ArkansasEntergy LouisianaEntergy MississippiEntergy New OrleansEntergy TexasSystem Energy
 (In Thousands)
Deferred tax liabilities:      
Plant basis differences - net($1,158,523)($3,429,473)($681,968)($192,660)($654,252)($433,874)
Regulatory assets(226,687)(530,274)(34,799)(30,694)(45,470)(61,205)
Nuclear decommissioning trusts/receivables(175,882)(186,382)— — — (153,610)
Pension, net regulatory asset(92,881)(93,681)(22,253)(11,429)(19,914)(18,033)
Deferred fuel(27,497)(13,686)(30,409)(1,600)(10,139)(49)
Accumulated storm damage provision— (193,967)— — (13,276)— 
Other(77,820)(138,299)(29,108)(33,071)(2,526)(5,622)
Total(1,759,290)(4,585,762)(798,537)(269,454)(745,577)(672,393)
Deferred tax assets:      
Regulatory liabilities310,256 634,184 59,418 36,057 55,022 224,036 
Nuclear decommissioning liabilities123,568 (909)(433)94 9,432 
Pension and other post-employment benefits(26,577)73,006 (7,793)(16,090)(18,793)(1,925)
Sale and leaseback— — — — — 102,474 
Accumulated deferred investment tax credit7,518 30,666 2,723 4,391 1,958 10,729 
Provision for allowances and contingencies24,829 21,768 10,236 5,559 7,730 — 
Power purchase agreements— — 1,140 — (1,202)— 
Unbilled/deferred revenues3,331 9,919 2,306 971 10,196 — 
Compensation3,347 5,288 2,181 1,036 1,618 447 
Net operating loss carryforwards275,054 1,228,547 166,008 105,549 81 — 
Capital losses and miscellaneous tax credits— 5,141 1,258 10,977 883 1,958 
Other19,397 5,968 2,891 7,788 863 
Total740,723 2,013,578 240,369 155,805 58,450 347,153 
Non-current accrued taxes (including unrecognized tax benefits)(397,634)138,330 (161,929)(251,735)(5,369)(57,691)
Accumulated deferred income taxes and taxes accrued($1,416,201)($2,433,854)($720,097)($365,384)($692,496)($382,931)
2020Entergy ArkansasEntergy LouisianaEntergy MississippiEntergy New OrleansEntergy TexasSystem Energy
 (In Thousands)
Deferred tax liabilities:      
Plant basis differences - net($1,117,948)($2,481,976)($623,796)($83,457)($620,669)($407,125)
Regulatory assets(188,284)(95,135)(22,381)(20,276)(47,684)(56,496)
Nuclear decommissioning trusts/receivables(156,123)(148,040)— — — (131,985)
Pension, net funding(93,486)(95,854)(24,922)(11,564)(19,481)(20,330)
Deferred fuel— (4,210)(1,706)(1,393)— (314)
Other(54,753)(76,735)(27,565)(26,334)(141)(12,521)
Total(1,610,594)(2,901,950)(700,370)(143,024)(687,975)(628,771)
Deferred tax assets:      
Regulatory liabilities273,774 218,278 56,022 31,248 47,991 163,534 
Nuclear decommissioning liabilities123,319 7,767 — (419)121 29,916 
Pension and other post-employment benefits(24,747)72,724 (6,763)(13,997)(17,132)(1,344)
Sale and leaseback— — — — — 102,477 
Accumulated deferred investment tax credit7,971 31,155 2,261 4,197 2,088 9,706 
Provision for allowances and contingencies22,179 7,071 16,799 24,529 (4,094)— 
Power purchase agreements9,662 3,381 1,140 (5,324)(30,932)— 
Unbilled/deferred revenues4,242 (23,382)2,989 877 5,909 — 
Compensation2,264 3,240 1,670 761 1,308 48 
Net operating loss carryforwards119,555 363,806 54,262 26,564 53,052 — 
Capital losses and miscellaneous tax credits— 9,309 — 12,317 — 7,014 
Other16,036 6,958 3,507 8,128 2,232 
Total554,255 700,307 131,887 88,881 60,543 311,353 
Non-current accrued taxes (including unrecognized tax benefits)(229,784)63,121 (78,191)(284,571)(11,990)(42,417)
Accumulated deferred income taxes and taxes accrued($1,286,123)($2,138,522)($646,674)($338,714)($639,422)($359,835)
The Registrant Subsidiaries’ estimated tax attributes carryovers and their expiration dates as of December 31, 2021 are as follows:

 Entergy ArkansasEntergy LouisianaEntergy MississippiEntergy New OrleansEntergy TexasSystem Energy
       
Federal net operating losses before 1/1/2018$— billion$1.7 billion$— billion$0.9 billion$— billion$— billion
Year(s) of expirationN/A2035-2037N/A2037N/AN/A
Federal net operating losses - 1/1/2018 forward$4.5 billion$4.5 billion$2.1 billion$0.7 billion$2.6 billion$— billion
Year(s) of expirationN/AN/AN/AN/AN/AN/A
       
State net operating losses$4.8 billion$7.2 billion$2.3 billion$1.7 billion$— million$— million
Year(s) of expiration2023-2026N/A2038-2041N/AN/AN/A
       
Misc. federal credits$4.7 million$12.3 million$1.8 million$15.3 million$3.1 million$1.5 million
Year(s) of expiration2038-20412035-20412038-20412037-20412036-20412036-2041
       
State credits$— million$— million$1.3 million$—million$2.9 million$9 million
Year(s) of expirationN/AN/A2022-2025N/A20272022-2025

As a result of the accounting for uncertain tax positions, the amount of the deferred tax assets reflected in the financial statements is less than the amount of the tax effect of the federal and state net operating loss carryovers and tax credit carryovers.

Unrecognized tax benefits

Accounting standards establish a “more-likely-than-not” recognition threshold that must be met before a tax benefit can be recognized in the financial statements.  If a tax deduction is taken on a tax return but does not meet the more-likely-than-not recognition threshold, an increase in income tax liability, above what is payable on the tax return, is required to be recorded.  A reconciliation of Entergy’s beginning and ending amount of unrecognized tax benefits is as follows:
 202120202019
 (In Thousands)
Gross balance at January 1$5,699,339 $7,383,154 $7,181,482 
Additions based on tax positions related to the current year101,623 669,207 731,276 
Additions for tax positions of prior years33,419 98,591 151,628 
Reductions for tax positions of prior years (74,413)(935,735)(681,232)
Settlements— (1,515,878)— 
Gross balance at December 315,759,968 5,699,339 7,383,154 
Offsets to gross unrecognized tax benefits:   
Loss and tax credit carryovers(4,987,799)(4,710,214)(5,831,587)
Cash paid to taxing authorities(60,000)(10,000)(10,000)
Unrecognized tax benefits net of unused tax attributes, refund claims and payments (a)$712,169 $979,125 $1,541,567 
(a)Potential tax liability above what is payable on tax returns

The balances of unrecognized tax benefits include $2,256 million, $2,208 million, and $2,421 million as of December 31, 2021, 2020, and 2019, respectively, which, if recognized, would lower the effective income tax rates.  Because of the effect of deferred tax accounting, the remaining balances of unrecognized tax benefits of $3,504 million, $3,491 million, and $4,962 million as of December 31, 2021, 2020, and 2019, respectively, if disallowed, would not affect the annual effective income tax rate but would accelerate the payment of cash to the taxing authority to an earlier period.

Entergy accrues interest expense, if any, related to unrecognized tax benefits in income tax expense.  Entergy’s December 31, 2021, 2020, and 2019 accrued balance for the possible payment of interest is approximately $52 million, $44 million, and $48 million, respectively. Interest (net-of-tax) of $8 million, ($4) million, and $4 million was recorded in 2021, 2020, and 2019, respectively.

A reconciliation of the Registrant Subsidiaries’ beginning and ending amount of unrecognized tax benefits for 2021, 2020, and 2019 is as follows:
2021Entergy ArkansasEntergy LouisianaEntergy MississippiEntergy New OrleansEntergy TexasSystem Energy
 (In Thousands)
Gross balance at January 1, 2021$1,364,635 $640,295 $549,717 $639,546 $521,932 $21,652 
Additions based on tax positions related to the current year30,419 13,437 684 1,050 32,616 1,753 
Additions for tax positions of prior years15,013 9,304 1,504 2,315 1,897 
Reductions for tax positions of prior years(1,573)(58,408)(2,336)(1,105)(4,568)(1,946)
Gross balance at December 31, 20211,408,494 604,628 549,569 639,497 552,295 23,356 
Offsets to gross unrecognized tax benefits:      
Loss and tax credit carryovers(992,643)(604,628)(388,728)(484,899)(540,694)(8,576)
Unrecognized tax benefits net of unused tax attributes and payments$415,851 $— $160,841 $154,598 $11,601 $14,780 

2020Entergy ArkansasEntergy LouisianaEntergy MississippiEntergy New OrleansEntergy TexasSystem Energy
 (In Thousands)
Gross balance at January 1, 2020$1,341,242 $2,381,653 $566,287 $716,773 $21,406 $473,331 
Additions based on tax positions related to the current year (a)9,403 35,681 5,619 2,430 504,362 4,013 
Additions for tax positions of prior years13,400 10,508 1,156 294 799 4,606 
Reductions for tax positions of prior years(11,346)(679,601)(24,173)(80,267)(5,559)(41,466)
Settlements11,936 (1,107,946)828 316 924 (418,832)
Gross balance at December 31, 20201,364,635 640,295 549,717 639,546 521,932 21,652 
Offsets to gross unrecognized tax benefits:      
Loss and tax credit carryovers(1,112,628)(640,295)(465,679)(451,922)(507,720)(7,413)
Unrecognized tax benefits net of unused tax attributes and payments$252,007 $— $84,038 $187,624 $14,212 $14,239 
2019Entergy ArkansasEntergy LouisianaEntergy MississippiEntergy New OrleansEntergy TexasSystem Energy
 (In Thousands)
Gross balance at January 1, 2019$1,298,662 $2,400,171 $508,765 $686,687 $17,802 $467,487 
Additions based on tax positions related to the current year84,335 28,705 68,594 40,676 2,312 5,496 
Additions for tax positions of prior years20,399 25,090 1,651 489 1,299 2,186 
Reductions for tax positions of prior years(62,154)(72,313)(12,723)(11,079)(7)(1,838)
Gross balance at December 31, 20191,341,242 2,381,653 566,287 716,773 21,406 473,331 
Offsets to gross unrecognized tax benefits:      
Loss and tax credit carryovers(1,134,187)(1,573,257)(506,976)(445,430)(3,944)(8,392)
Unrecognized tax benefits net of unused tax attributes and payments$207,055 $808,396 $59,311 $271,343 $17,462 $464,939 

(a)The primary additions for Entergy Texas in 2020 are related to the mark-to-market treatment discussed in “Other Tax Matters - Tax Accounting Methods” below.

The Registrant Subsidiaries’ balances of unrecognized tax benefits included amounts which, if recognized, would have reduced income tax expense as follows:
December 31,
 202120202019
 (In Millions)
Entergy Arkansas$262.1 $259.3 $203.3 
Entergy Louisiana$66.3 $63.8 $556.3 
Entergy Mississippi$51.7 $50.7 $1.9 
Entergy New Orleans$228.6 $203.5 $242.7 
Entergy Texas$2.6 $6.1 $5.7 
System Energy$1.7 $0.5 $— 

Accrued balances for the possible payment of interest related to unrecognized tax benefits are as follows:
December 31,
 202120202019
 (In Millions)
Entergy Arkansas$2.7 $2.3 $3.1 
Entergy Louisiana$3.7 $3.4 $14.2 
Entergy Mississippi$2.4 $1.9 $1.7 
Entergy New Orleans$5.2 $3.9 $4.7 
Entergy Texas$1.1 $0.9 $1.1 
System Energy$12.1 $11.9 $14.5 
The Registrant Subsidiaries record interest and penalties related to unrecognized tax benefits in income tax expense.  No penalties were recorded in 2021, 2020, and 2019. Interest (net-of-tax) was recorded as follows:
202120202019
(In Millions)
Entergy Arkansas$0.4 ($0.8)$1.4 
Entergy Louisiana$0.3 ($10.8)($3.7)
Entergy Mississippi$0.5 $0.2 $0.5 
Entergy New Orleans$1.3 ($0.8)$2.0 
Entergy Texas$0.2 ($0.2)$0.2 
System Energy$0.2 ($2.6)$1.3 

Income Tax Audits

Entergy and its subsidiaries file U.S. federal and various state income tax returns.  IRS examinations are complete for years before 2016. All state taxing authorities’ examinations are complete for years before 2014. Entergy regularly defends its positions and works with the IRS to resolve audits.  The resolution of audit issues could result in significant changes to the amounts of unrecognized tax benefits in the next twelve months.

2014-2015 IRS Audit

The IRS completed its examination of the 2014 and 2015 tax years and issued its 2014-2015 RAR in November 2020. Entergy agreed to all proposed adjustments contained in the RAR. Entergy and the Registrant Subsidiaries recorded the effects of the adjustments associated with the audit in 2020.

In October 2015 two of Entergy’s Louisiana utilities, Entergy Gulf States Louisiana and Entergy Louisiana, combined their businesses into a legal entity which is identified as Entergy Louisiana herein. The structure of the business combination required Entergy to recognize a gain for income tax purposes which resulted in an increase in the tax basis of the assets for Entergy Louisiana. This resulted in recognition in 2015 of a $334 million permanent difference and income tax benefit, net of the uncertain tax position recorded on the transaction.

Primarily related to resolution of the business combination issues, completion of the 2014-2015 IRS audit in 2020 resulted in a $230 million reduction to deferred income tax expense for Entergy. This reduction to deferred income tax expense includes: Entergy Louisiana reversing its provision for uncertain tax position with respect to the business combination, which resulted in a reduction to deferred income tax expense of $383 million; Entergy Corporation recording an increase to deferred tax expense of $61 million and Entergy Wholesale Commodities recording an increase to deferred tax expense of $105 million from the re-measurement of deferred tax assets associated with the resolved uncertain tax position; and miscellaneous other individually insignificant benefits totaling $13 million.

The completion of the 2014-2015 tax audit also resulted in a $31 million reduction to income tax expense associated with Entergy Louisiana’s method of accounting related to the adoption of tangible property regulations. As a result of the settlement of the tangible property regulation tax position, Entergy Louisiana was required to record a $33 million ($24 million net-of-tax) regulatory charge and a corresponding regulatory liability to reflect its obligation to customers pursuant to a prior regulatory settlement.

Finally, upon completion of the 2014-2015 tax audit, Entergy New Orleans recorded a reduction to income tax expense of $8 million associated with claims for mark-to-market deductions.

In the first quarter 2020, Entergy and the IRS agreed on the treatment of funds received by Entergy Louisiana in conjunction with the Act 55 financing of Hurricane Isaac storm costs, which resulted in a net reduction
of income tax expense of approximately $32 million. As a result of the settlement, the position was partially sustained, and Entergy Louisiana recorded a reduction of income tax expense of approximately $58 million primarily due to the reversal of a provision for uncertain tax positions in excess of the agreed-upon settlement. As a result of the IRS settlement, Entergy Louisiana recorded a $29 million ($21 million net-of-tax) regulatory charge and a corresponding regulatory liability to reflect its obligation to customers pursuant to the LPSC Hurricane Isaac Act 55 financing order.

Additional effects of the completion of the 2014-2015 IRS tax audit are discussed below within Tax Accounting Methods.

Other Tax Matters

Tax Cuts and Jobs Act (TCJA)

The most significant effect of the TCJA for Entergy and the Registrant Subsidiaries was the change in the federal corporate income tax rate from 35% to 21%, effective January 1, 2018.

TCJA also limited the deduction for net business interest expense to 30 percent of adjusted taxable income, which is similar to earnings before interest, taxes, depreciation, and amortization. The limitation does not apply to interest expense that is properly allocable to a trade or business classified as a regulated public utility. This was further modified by a temporary provision of the CARES Act resulting in an increase of the adjusted taxable income limitation from 30% to 50% for tax years that begin in 2019 or 2020.

The IRS issued final regulations which are effective for Entergy beginning with the 2021 tax year. The regulations provide that if 90% of a tax group’s consolidated assets consist of regulated utility property, the entire consolidated tax group will be treated as a regulated public utility and all of the consolidated group’s interest expense will be currently tax deductible. Entergy expects that this provision will continue to apply to Entergy’s business operations making the application of this limitation to Entergy less likely. The provision has not resulted in Entergy having to report any significant business interest expense limitations on its tax returns.

With respect to the federal corporate income tax rate change from 35% to 21% in 2017, Entergy and the Registrant Subsidiaries recorded a regulatory liability associated with the decrease in the net accumulated deferred income tax liability, which is often referred to as “excess ADIT,” a significant portion of which has been paid to customers in 2019, 2020 and 2021 in the form of lower rates. Entergy’s December 31, 2021 and December 31, 2020 balance sheets reflect a regulatory liability of $1.3 billion and $1.6 billion, respectively, as a result of the re-measurement of deferred tax assets and liabilities from the income tax rate change, amortization of excess ADIT, and payments to customers during 2019, 2020 and 2021. Entergy’s regulatory liability for income taxes includes a gross-up at the applicable tax rate because of the effect that excess ADIT has on the ratemaking formula. The regulatory liability for income taxes includes the effect of a) the reduction of the net deferred tax liability resulting in excess ADIT, and b) the tax gross-up of excess ADIT. The Registrant Subsidiaries’ December 31, 2021 and December 31, 2020 balance sheets reflect net regulatory liabilities for income taxes as follows:
20212020
(In Millions)
Entergy Arkansas$432 $467 
Entergy Louisiana$338 $479 
Entergy Mississippi$212 $224 
Entergy New Orleans$42 $59 
Entergy Texas$171 $205 
System Energy$113 $152 
Excess ADIT is generally classified into two categories: 1) the portion that is subject to the normalization requirements of the TCJA, i.e., “protected”, and 2) the portion that is not subject to such normalization provisions, referred to as “unprotected”. The TCJA provides that the normalization method of accounting for income taxes is required for excess ADIT associated with public utility property. The TCJA provides for the use of the average rate assumption method (ARAM) for the determination of the timing of the return of excess ADIT associated with such property. Under ARAM, the excess ADIT is reduced over the remaining life of the asset. Remaining asset lives vary for each Registrant Subsidiary, but the average life of public utility property is typically 30 years or longer. Entergy will amortize the protected portion of the excess ADIT in conformity with the normalization requirements. The Registrant Subsidiaries’ net regulatory liability for income taxes as of December 31, 2021 and December 31, 2020, includes protected excess ADIT as follows:
20212020
(In Millions)
Entergy Arkansas$463 $490 
Entergy Louisiana$669 $721 
Entergy Mississippi$237 $248 
Entergy New Orleans$56 $61 
Entergy Texas$208 $215 
System Energy$148 $173 

Payment of the unprotected excess accumulated deferred income taxes results in a reduction in the regulatory liability for income taxes and a corresponding reduction in income tax expense. This has a significant effect on the effective tax rate for the period as compared to the statutory tax rate. The Registrant Subsidiaries’ net regulatory liability for income taxes as of December 31, 2021 and December 31, 2020, includes unprotected excess ADIT as follows:
20212020
(In Millions)
Entergy Arkansas$12 $11 
Entergy Louisiana$148 $223 
Entergy New Orleans$— $3 
Entergy Texas$26 $54 
System Energy$— $16 

The return of unprotected excess accumulated deferred income taxes reduced Entergy’s and the Registrant Subsidiaries’ regulatory liability for income taxes as follows for 2021 and 2020:
20212020
(In Millions)
Entergy$88 $74 
Entergy Arkansas$8 $8 
Entergy Louisiana$33 $31 
Entergy New Orleans$1 $6 
Entergy Texas$28 $29 
System Energy$18 $— 

In addition to the protected and unprotected excess ADIT amounts, the net regulatory liability for income taxes includes other regulatory assets and liabilities for income taxes associated with AFUDC, which is described in Note 1 to the financial statements.
Included in the effect of the computation of the changes in deferred tax assets and liabilities is the recognition threshold and measurement of uncertain tax positions resulting in unrecognized tax benefits. The final economic outcome of such unrecognized tax benefits is generally the result of a negotiated settlement with the IRS that often differs from the amount that is recorded as realizable under GAAP. The intrinsic uncertainty with respect to all such tax positions means that the difference between current estimates of such amounts likely to be realized and actual amounts realized upon settlement may have an effect on income tax expense and the regulatory liability for income taxes in future periods.

Entergy anticipates that the effect of TCJA may continue to have ramifications that require adjustments in the future as certain events occur. These events include: 1) IRS audit adjustments to or amendments of federal and state income tax returns that include modifications to the computation of taxable income resulting from TCJA; and 2) additional guidance, interpretations, or rulings by the U.S. Department of the Treasury or the IRS. The potential exists for these types of events to result in future tax expense adjustments because of the difference in the federal corporate income tax rate between past and future periods and the effect of the tax rate change on ratemaking. In turn, these events also could potentially affect the regulatory liability for income taxes.

Coronavirus Aid, Relief, and Economic Security Act

In response to the economic impacts of the COVID-19 pandemic, President Trump signed the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) into law on March 27, 2020. The CARES Act provisions that result in the most significant opportunities for tax relief to Entergy and the Registrant Subsidiaries are (i) permitting a five-year carryback of 2018-2020 NOLs, (ii) removing the 80 percent limitation on NOLs carried to tax years beginning before 2021, (iii) increasing the limitation on interest expense deductibility for 2019 and 2020, (iv) accelerating available refunds for minimum tax credit carryforwards, modifying limitations on charitable contributions during 2020, and (v) delaying the payment of employer payroll taxes. Entergy deferred approximately $64 million of 2020 payroll tax payments, payable in equal installments over two years. The initial installment of $32 million was paid in December 2021. The second installment will be paid in December 2022.

Entergy Wholesale Commodities Restructuring

In the fourth quarter 2019, two separate events occurred resulting in a reduction of tax expense of $174 million. In November 2019 an Entergy Wholesale Commodities subsidiary recognized a reduction in income tax expense of $18 million in connection with the accounting method on power contracts associated with the Palisades nuclear power station. Additionally, Entergy’s ownership of Indian Point 2 and Indian Point 3 was restructured. The restructuring required Entergy to recognize Indian Point 2 and Indian Point 3 nuclear decommissioning liabilities for income tax purposes resulting in a tax accounting permanent difference that reduced income tax expense, net of unrecognized tax benefits, by $156 million. The accrual of the nuclear decommissioning liabilities also required Entergy to recognize a gain for income tax purposes, a portion of which resulted in an increase in the tax basis of the assets. Recognition of the gain and the increase in the tax basis of the assets represents a tax accounting temporary difference.

Immediately prior to the restructuring, through its ownership of Indian Point 2 and Indian Point 3, Entergy donated property to Stony Brook University and recognized an associated tax deduction resulting in a decrease to tax expense of $19 million.

In the fourth quarter 2020, Entergy’s ownership of Palisades was restructured. The restructuring required Entergy to recognize Palisades’ nuclear decommissioning liability for income tax purposes resulting in a tax accounting permanent difference that reduced income tax expense, net of unrecognized tax benefits, by $9.2 million. The accrual of the nuclear decommissioning liability also required Entergy to recognize a gain for income tax purposes, a portion of which resulted in an increase in the tax basis of the assets. Recognition of the gain and the increase in the tax basis of the assets represents a tax accounting temporary difference.
Tax Accounting Methods

In the fourth quarter 2015, System Energy and Entergy Louisiana adopted a new method of accounting for income tax return purposes in which their nuclear decommissioning costs will be treated as production costs of electricity includable in cost of goods sold. The new method resulted in a reduction of taxable income of $1.2 billion for System Energy and $2.2 billion for Energy Louisiana.

In conjunction with the 2014-2015 IRS audit discussed above, the IRS issued proposed adjustments concerning the nuclear decommissioning tax position allowing System Energy to include $102 million of its decommissioning liability in cost of goods sold, and Entergy Louisiana to include $221 million of its decommissioning liability in cost of goods sold. Entergy, System Energy, and Entergy Louisiana agreed to the proposed adjustments included in the RAR.

As a result of System Energy being allowed to include part of its decommissioning liability in cost of goods sold, System Energy and Entergy recorded a deferred tax liability of $26 million. System Energy also recorded federal and state taxes payable of $402 million. However, on a consolidated basis, Entergy utilized tax loss carryovers to offset the federal taxable income adjustment and did not record federal taxes payable as a result of the outcome of this uncertain tax position.

As a result of Entergy Louisiana being allowed to include part of its decommissioning liability in cost of goods sold, Entergy Louisiana and Entergy recorded a deferred tax liability of $60 million. Both Entergy Louisiana and Entergy utilized tax loss carryovers to offset the taxable income adjustment and accordingly did not record taxes payable as a result of the outcome of this uncertain tax position.

The partial disallowance of this uncertain tax position to include the decommissioning liability in cost of goods sold resulted in a $1.5 billion decrease in the balance of unrecognized tax benefits related to federal and state taxes for Entergy. Additionally, both System Energy and Entergy Louisiana recorded a reduction to their balances of unrecognized tax benefits for federal and state taxes of $461 million and $1.1 billion, respectively.

Entergy Arkansas adopted the same method of accounting for its nuclear decommissioning costs which resulted in a $1.8 billion reduction in taxable income on its 2018 tax return.

In 2016, Entergy Louisiana elected mark-to-market income tax treatment for various wholesale electric power purchase and sale agreements, including Entergy Louisiana’s contract to purchase electricity from the Vidalia hydroelectric facility and from System Energy under the Unit Power Sales Agreement. The election resulted in a $2.2 billion deductible temporary difference. In 2017, Entergy New Orleans also elected mark-to-market income tax treatment for wholesale electric contracts which resulted in a $1.1 billion deductible temporary difference. In 2018, Entergy Arkansas and Entergy Mississippi accrued deductible temporary differences related to mark-to-market tax accounting for wholesale electric contracts of $2.1 billion and $1.9 billion, respectively. Additionally, in 2020, Entergy Texas elected mark-to-market income tax treatment for wholesale electric power purchase and sale agreements which resulted in a $2.5 billion deductible temporary difference.

Arkansas and Louisiana Corporate Income Tax Rate Changes

In April 2019 and December 2021 the State of Arkansas enacted corporate income tax law changes that phased in rate reductions from the former rate of 6.5% to 6.2% in 2021, 5.9% in 2022, and 5.7% in 2023.    As a result of the 2019 rate reduction, Entergy Arkansas computed a regulatory liability for income taxes as of December 31, 2020 of approximately $21 million, which includes a tax gross-up related to the treatment of income taxes in the retail and wholesale ratemaking formulas and has been included in the appropriate rate mechanisms. Entergy Arkansas recorded an incremental regulatory liability of $11 million associated with the rate reduction enacted in December 2021. The Arkansas tax law enactment also phases in an increase to the net operating loss carryover period from five to ten years.
Pursuant to legislation enacted in 2021 and approved by Louisiana citizens by amendment to the state constitution, beginning January 1, 2022, federal income taxes paid will no longer be deductible for state income tax purposes, and the top Louisiana corporate income tax rate will be reduced from 8% to 7.5%. As a result of this change in Louisiana tax law, the Louisiana applicable tax rate increased by 0.85%. Accordingly, deferred tax assets and liabilities were adjusted to reflect the new applicable federal and state rates. Legislation enacted in 2021 also provides that Louisiana net operating losses generally have an indefinite carryover period.

Entergy recorded a net increase to its deferred tax asset of $27 million. Entergy Louisiana and Entergy New Orleans recorded net increases to their deferred tax liabilities before consideration of the tax gross-up of $77 million and $8 million, respectively, which were offset by regulatory assets for income taxes. Therefore, these increases had no effect on tax expense. However, the increase of deferred tax assets associated with certain assets reduced tax expense for Entergy Louisiana and Entergy New Orleans by $6 million and $2 million, respectively.

Consolidated Income Tax Return of Entergy Corporation

In September 2019, Entergy Utility Holding Company, LLC and its regulated, wholly-owned subsidiaries including Entergy Arkansas, Entergy Louisiana, Entergy Mississippi, and Entergy New Orleans, became eligible to and joined the Entergy Corporation consolidated federal income tax group.  As a result of these four Utility operating companies re-joining the Entergy Corporation consolidated tax return group, Entergy was able to recognize a $41 million deferred tax asset associated with a previously unrecognized net operating loss carryover.

In September 2019, Entergy Texas issued $35 million of 5.375% Series A preferred stock with a liquidation value of $25 per share resulting in the disaffiliation and de-consolidation of Entergy Texas from the consolidated federal income tax return of Entergy Corporation.  These changes will not affect the accrual or allocation of income taxes for the Registrant Subsidiaries. See Note 6 to the financial statements for discussion of the preferred stock issuance.

Vermont Yankee

The Vermont Yankee transaction resulted in Entergy generating a net deferred tax asset in January 2019.  The deferred tax asset could not be fully realized by Entergy in the first quarter 2019; accordingly, Entergy accrued a net tax expense of $29 million on the disposition of Vermont Yankee. See Note 14 to the financial statements for discussion of the Vermont Yankee transaction.

Stock Compensation

In accordance with stock compensation accounting rules, Entergy and the Registrant Subsidiaries recognized excess tax deductions as a reduction of income tax expense in the first quarter 2020. Due to the vesting and exercise of certain Entergy stock-based awards, Entergy recorded a permanent tax reduction of approximately $24.7 million, including $4.8 million for Entergy Arkansas, $8.6 million for Entergy Louisiana, $2.7 million for Entergy Mississippi, $1.5 million for Entergy New Orleans, $2.7 million for Entergy Texas, and $1.3 million for System Energy.
Entergy New Orleans [Member]  
Income Taxes INCOME TAXES (Entergy Corporation, Entergy Arkansas, Entergy Louisiana, Entergy Mississippi, Entergy New Orleans, Entergy Texas, and System Energy)
Income taxes for 2021, 2020, and 2019 for Entergy Corporation and Subsidiaries consist of the following:
 202120202019
 (In Thousands)
Current:   
Federal($5,003)$5,807 ($14,416)
State(8,995)57,939 6,535 
Total(13,998)63,746 (7,881)
Deferred and non-current - net205,891 (190,635)(155,956)
Investment tax credit adjustments - net(519)5,383 (5,988)
Income taxes$191,374 ($121,506)($169,825)

Income taxes for 2021, 2020, and 2019 for Entergy’s Registrant Subsidiaries consist of the following:
2021Entergy ArkansasEntergy LouisianaEntergy MississippiEntergy New OrleansEntergy TexasSystem Energy
(In Thousands)
Current:      
Federal($20,285)($24,053)($5,868)($6,724)($189)$29,416 
State529 2,459 (11,506)(413)1,261 (10,258)
Total(19,756)(21,594)(17,374)(7,137)1,072 19,158 
Deferred and non-current - net96,180 146,786 60,861 12,870 25,087 (25,229)
Investment tax credit adjustments - net(1,229)(4,783)1,836 203 (633)4,094 
Income taxes$75,195 $120,409 $45,323 $5,936 $25,526 ($1,977)

2020Entergy ArkansasEntergy LouisianaEntergy MississippiEntergy New OrleansEntergy TexasSystem Energy
 (In Thousands)
Current:      
Federal($44,627)$62,728 ($14,580)$293 ($5,603)$372,206 
State(2,563)4,457 (1,316)(303)2,658 55,551 
Total(47,190)67,185 (15,896)(10)(2,945)427,757 
Deferred and non-current - net96,195 (444,647)43,640 (18,153)6,619 (405,928)
Investment tax credit adjustments - net(1,228)(4,862)(554)13,956 (632)(1,286)
Income taxes$47,777 ($382,324)$27,190 ($4,207)$3,042 $20,543 
2019Entergy ArkansasEntergy LouisianaEntergy MississippiEntergy New OrleansEntergy TexasSystem Energy
 (In Thousands)
Current:      
Federal($14,549)($20,173)($8,939)($5,822)$16,035 $16,256 
State(714)(735)5,823 1,856 663 (2,831)
Total(15,263)(20,908)(3,116)(3,966)16,698 13,425 
Deferred and non-current - net(30,278)147,453 34,579 4,248 (69,963)422 
Investment tax credit adjustments - net(1,228)(4,922)(597)(96)(631)1,502 
Income taxes($46,769)$121,623 $30,866 $186 ($53,896)$15,349 

Total income taxes for Entergy Corporation and Subsidiaries differ from the amounts computed by applying the statutory income tax rate to income before income taxes.  The reasons for the differences for the years 2021, 2020, and 2019 are:
 202120202019
 (In Thousands)
Net income attributable to Entergy Corporation$1,118,492 $1,388,334 $1,241,226 
Preferred dividend requirements of subsidiaries227 18,319 17,018 
Consolidated net income1,118,719 1,406,653 1,258,244 
Income taxes191,374 (121,506)(169,825)
Income before income taxes$1,310,093 $1,285,147 $1,088,419 
Computed at statutory rate (21%)$275,120 $269,881 $228,568 
Increases (reductions) in tax resulting from:   
State income taxes net of federal income tax effect79,273 60,087 61,791 
Regulatory differences - utility plant items(57,556)(53,229)(45,336)
Equity component of AFUDC(14,799)(25,080)(30,444)
Amortization of investment tax credits(7,695)(8,386)(8,093)
Flow-through / permanent differences(5,585)11,099 (2,059)
Amortization of excess ADIT (a)(66,478)(59,629)(205,614)
Arkansas and Louisiana Rate Changes (b)(27,108)— — 
IRS audit adjustment (d)— (301,041)— 
Entergy Wholesale Commodities restructuring (c)— (9,223)(173,725)
Stock compensation (e)— (25,591)— 
Charitable contribution (c)— — (19,101)
Net operating loss recognition— — (41,427)
Provision for uncertain tax positions16,533 15,208 7,332 
Valuation allowance(2,600)— 59,345 
Other - net2,269 4,398 (1,062)
Total income taxes as reported$191,374 ($121,506)($169,825)
Effective Income Tax Rate14.6 %(9.5 %)(15.6 %)

(a)See “Other Tax Matters - Tax Cuts and Jobs Act” below for discussion of the amortization of excess accumulated deferred income taxes (ADIT) in 2019, 2020, and 2021 and the tax legislation enactment in 2017.
(b)See “Arkansas and Louisiana Corporate Income Tax Rate Changes” below for details.
(c)See Other Tax Matters - Entergy Wholesale Commodities Restructuring” below for discussion of the Entergy Wholesale Commodities restructuring in 2019, the ownership of Palisades restructuring in 2020, and the charitable contribution in 2019.
(d)See “Income Tax Audits - 2014-2015 IRS Audit” below for discussion of the resolution of the audit in 2020.
(e)See “Other Tax Matters - Stock Compensation” below for discussion of excess tax deductions.

Total income taxes for the Registrant Subsidiaries differ from the amounts computed by applying the statutory income tax rate to income before taxes.  The reasons for the differences for the years 2021, 2020, and 2019 are:
2021Entergy ArkansasEntergy LouisianaEntergy MississippiEntergy New OrleansEntergy TexasSystem Energy
 (In Thousands)
Net income$298,484 $653,984 $166,834 $31,798 $228,824 $106,814 
Income taxes75,195 120,409 45,323 5,936 25,526 (1,977)
Pretax income$373,679 $774,393 $212,157 $37,734 $254,350 $104,837 
Computed at statutory rate (21%)$78,473 $162,623 $44,553 $7,924 $53,413 $22,016 
Increases (reductions) in tax resulting from:     
State income taxes net of federal income tax effect19,633 41,030 9,305 2,579 1,553 5,385 
Regulatory differences - utility plant items(16,078)(14,123)(8,133)(4,332)(2,115)(12,776)
Equity component of AFUDC(3,207)(6,016)(1,701)(498)(2,077)(1,300)
Amortization of investment tax credits(1,201)(4,729)64 (56)(617)(1,155)
Flow-through / permanent differences(814)(2,655)124 1,559 (475)(1,235)
Amortization of excess ADIT (a)(5,845)(24,323)— (1,028)(21,929)(13,354)
Arkansas and Louisiana Rate Changes (b)398 (6,126)395 (1,569)216 115 
Non-taxable dividend income— (26,801)— — — — 
Provision for uncertain tax positions353 300 465 1,200 (2,716)200 
Valuation Allowance2,766 — — — — — 
Other - net717 1,229 251 157 273 127 
Total income taxes as reported$75,195 $120,409 $45,323 $5,936 $25,526 ($1,977)
Effective Income Tax Rate20.1 %15.5 %21.4 %15.7 %10.0 %(1.9 %)
2020Entergy ArkansasEntergy LouisianaEntergy MississippiEntergy New OrleansEntergy TexasSystem Energy
 (In Thousands)
Net income$245,232 $1,082,352 $140,583 $49,338 $215,073 $99,131 
Income taxes47,777 (382,324)27,190 (4,207)3,042 20,543 
Pretax income$293,009 $700,028 $167,773 $45,131 $218,115 $119,674 
Computed at statutory rate (21%)$61,532 $147,006 $35,232 $9,478 $45,804 $25,132 
Increases (reductions) in tax resulting from:
State income taxes net of federal income tax effect16,256 38,182 6,917 2,606 1,460 5,524 
Regulatory differences - utility plant items(8,034)(23,819)(7,441)(3,442)(7,673)(2,821)
Equity component of AFUDC(3,154)(8,012)(1,412)(1,331)(9,255)(1,916)
Amortization of investment tax credits(1,201)(4,811)(540)(61)(617)(1,155)
Flow-through / permanent differences(2,219)1,404 (102)498 766 (421)
Amortization of excess ADIT (a)(6,011)(26,293)18 (4,564)(22,780)— 
Stock compensation (d)(4,952)(9,004)(2,763)(1,526)(2,842)(1,300)
IRS audit adjustment (c)(6,351)(471,702)(3,768)(6,819)(2,091)(2,925)
Non-taxable dividend income— (26,795)— — — — 
Provision for uncertain tax positions1,200 300 800 800 — 300 
Other - net711 1,220 249 154 270 125 
Total income taxes as reported$47,777 ($382,324)$27,190 ($4,207)$3,042 $20,543 
Effective Income Tax Rate16.3 %(54.6 %)16.2 %(9.3 %)1.4 %17.2 %

2019Entergy ArkansasEntergy LouisianaEntergy MississippiEntergy New OrleansEntergy TexasSystem Energy
 (In Thousands)
Net income$262,964 $691,537 $119,925 $52,629 $159,397 $99,120 
Income taxes(46,769)121,623 30,866 186 (53,896)15,349 
Pretax income$216,195 $813,160 $150,791 $52,815 $105,501 $114,469 
Computed at statutory rate (21%)$45,401 $170,764 $31,666 $11,091 $22,155 $24,039 
Increases (reductions) in tax resulting from:      
State income taxes net of federal income tax effect15,954 42,854 5,563 3,443 360 5,134 
Regulatory differences - utility plant items(10,627)(19,421)(5,556)(1,532)(1,987)(6,213)
Equity component of AFUDC(3,255)(15,545)(1,755)(2,088)(5,973)(1,829)
Amortization of investment tax credits(1,201)(4,871)(160)(88)(617)(1,155)
Flow-through / permanent differences696 439 160 (741)560 (500)
Amortization of excess ADIT (a)(90,921)(28,531)203 (11,724)(69,091)(5,550)
Non-taxable dividend income— (26,795)— — — — 
Provision for uncertain tax positions(3,517)1,519 500 1,672 430 1,300 
Other - net701 1,210 245 153 267 123 
Total income taxes as reported($46,769)$121,623 $30,866 $186 ($53,896)$15,349 
Effective Income Tax Rate(21.6 %)15.0 %20.5 %0.4 %(51.1 %)13.4 %
(a)See “Other Tax Matters - Tax Cuts and Jobs Act” below for discussion of the amortization of excess accumulated deferred income taxes (ADIT) in 2019, 2020 and 2021 and the tax legislation enactment in 2017.
(b)See “Arkansas and Louisiana Corporate Income Tax Rate Changes” below for details.
(c)See “Income Tax Audits - 2014-2015 IRS Audit” below for discussion of the resolution of the audit in 2020.
(d)See “Other Tax Matters - Stock Compensation” below for discussion of excess tax deductions.


Significant components of accumulated deferred income taxes and taxes accrued for Entergy Corporation and Subsidiaries as of December 31, 2021 and 2020 are as follows:
 
 20212020
 (In Thousands)
Deferred tax liabilities:  
Plant basis differences - net($6,136,563)($4,795,422)
Regulatory assets(930,244)(429,996)
Nuclear decommissioning trusts/receivables(656,185)(1,188,235)
Pension, net regulatory asset(322,788)(327,445)
Combined unitary state taxes(7,255)(7,723)
Unbilled/deferred revenues— (9,152)
Accumulated storm damage provision(207,243)— 
Deferred fuel(85,310)(7,667)
Other(341,450)(549,355)
Total(8,687,038)(7,314,995)
Deferred tax assets:  
Nuclear decommissioning liabilities278,136 968,464 
Regulatory liabilities1,318,381 791,927 
Pension and other post-employment benefits208,128 278,486 
Sale and leaseback102,474 102,477 
Compensation79,798 89,279 
Accumulated deferred investment tax credit57,986 57,379 
Provision for allowances and contingencies82,286 71,598 
Power purchase agreements55,259 352,019 
Unbilled/deferred revenues26,683 — 
Net operating loss carryforwards2,868,424 1,580,109 
Capital losses and miscellaneous tax credits11,111 21,291 
Valuation allowance(325,239)(328,581)
Other200,032 230,291 
Total4,963,459 4,214,739 
Non-current accrued taxes (including unrecognized tax benefits)(929,032)(1,185,227)
Accumulated deferred income taxes and taxes accrued($4,652,611)($4,285,483)
Entergy’s estimated tax attributes carryovers and their expiration dates as of December 31, 2021 are as follows:
Carryover DescriptionCarryover AmountYear(s) of expiration
   
Federal net operating losses before 1/1/2018$6.2 billion2023-2027
Federal net operating losses - 1/1/2018 forward$21.1 billionN/A
State net operating losses$7.4 billion2022-2041
State net operating losses with no expiration$16.7 billionN/A
Federal and state charitable contributions$460.8 million2022-2026
Miscellaneous federal and state credits$73.1 million2022-2041

As a result of the accounting for uncertain tax positions, the amount of the deferred tax assets reflected in the financial statements is less than the amount of the tax effect of the federal and state net operating loss carryovers, tax credit carryovers, and other tax attributes reflected on income tax returns. Entergy evaluates the available positive and negative evidence to estimate whether sufficient future taxable income of the appropriate character will be generated to realize the benefits of existing deferred tax assets. When the evaluation indicates that Entergy will not be able to realize the existing benefits, a valuation allowance is recorded to reduce deferred tax assets to the realizable amount.

Because it is more likely than not that the benefits from certain state net operating losses and other deferred tax assets will not be utilized, valuation allowances totaling $325 million as of December 31, 2021 and $329 million as of December 31, 2020 have been provided on the deferred tax assets related to federal and state jurisdictions in which Entergy does not currently expect to be able to utilize certain separate company tax return attributes, preventing realization of such deferred tax assets. As a result of incurring costs related to Hurricane Ida restoration, certain Utility operating companies are entitled to an accelerated tax deduction which generated a taxable loss in various taxing jurisdictions. This accelerated deduction has impaired the realizability of a limited term carryover tax attribute. Accordingly, the impairment contributed to the activity reflected for the valuation allowance disclosed above.
Significant components of accumulated deferred income taxes and taxes accrued for the Registrant Subsidiaries as of December 31, 2021 and 2020 are as follows:
2021Entergy ArkansasEntergy LouisianaEntergy MississippiEntergy New OrleansEntergy TexasSystem Energy
 (In Thousands)
Deferred tax liabilities:      
Plant basis differences - net($1,158,523)($3,429,473)($681,968)($192,660)($654,252)($433,874)
Regulatory assets(226,687)(530,274)(34,799)(30,694)(45,470)(61,205)
Nuclear decommissioning trusts/receivables(175,882)(186,382)— — — (153,610)
Pension, net regulatory asset(92,881)(93,681)(22,253)(11,429)(19,914)(18,033)
Deferred fuel(27,497)(13,686)(30,409)(1,600)(10,139)(49)
Accumulated storm damage provision— (193,967)— — (13,276)— 
Other(77,820)(138,299)(29,108)(33,071)(2,526)(5,622)
Total(1,759,290)(4,585,762)(798,537)(269,454)(745,577)(672,393)
Deferred tax assets:      
Regulatory liabilities310,256 634,184 59,418 36,057 55,022 224,036 
Nuclear decommissioning liabilities123,568 (909)(433)94 9,432 
Pension and other post-employment benefits(26,577)73,006 (7,793)(16,090)(18,793)(1,925)
Sale and leaseback— — — — — 102,474 
Accumulated deferred investment tax credit7,518 30,666 2,723 4,391 1,958 10,729 
Provision for allowances and contingencies24,829 21,768 10,236 5,559 7,730 — 
Power purchase agreements— — 1,140 — (1,202)— 
Unbilled/deferred revenues3,331 9,919 2,306 971 10,196 — 
Compensation3,347 5,288 2,181 1,036 1,618 447 
Net operating loss carryforwards275,054 1,228,547 166,008 105,549 81 — 
Capital losses and miscellaneous tax credits— 5,141 1,258 10,977 883 1,958 
Other19,397 5,968 2,891 7,788 863 
Total740,723 2,013,578 240,369 155,805 58,450 347,153 
Non-current accrued taxes (including unrecognized tax benefits)(397,634)138,330 (161,929)(251,735)(5,369)(57,691)
Accumulated deferred income taxes and taxes accrued($1,416,201)($2,433,854)($720,097)($365,384)($692,496)($382,931)
2020Entergy ArkansasEntergy LouisianaEntergy MississippiEntergy New OrleansEntergy TexasSystem Energy
 (In Thousands)
Deferred tax liabilities:      
Plant basis differences - net($1,117,948)($2,481,976)($623,796)($83,457)($620,669)($407,125)
Regulatory assets(188,284)(95,135)(22,381)(20,276)(47,684)(56,496)
Nuclear decommissioning trusts/receivables(156,123)(148,040)— — — (131,985)
Pension, net funding(93,486)(95,854)(24,922)(11,564)(19,481)(20,330)
Deferred fuel— (4,210)(1,706)(1,393)— (314)
Other(54,753)(76,735)(27,565)(26,334)(141)(12,521)
Total(1,610,594)(2,901,950)(700,370)(143,024)(687,975)(628,771)
Deferred tax assets:      
Regulatory liabilities273,774 218,278 56,022 31,248 47,991 163,534 
Nuclear decommissioning liabilities123,319 7,767 — (419)121 29,916 
Pension and other post-employment benefits(24,747)72,724 (6,763)(13,997)(17,132)(1,344)
Sale and leaseback— — — — — 102,477 
Accumulated deferred investment tax credit7,971 31,155 2,261 4,197 2,088 9,706 
Provision for allowances and contingencies22,179 7,071 16,799 24,529 (4,094)— 
Power purchase agreements9,662 3,381 1,140 (5,324)(30,932)— 
Unbilled/deferred revenues4,242 (23,382)2,989 877 5,909 — 
Compensation2,264 3,240 1,670 761 1,308 48 
Net operating loss carryforwards119,555 363,806 54,262 26,564 53,052 — 
Capital losses and miscellaneous tax credits— 9,309 — 12,317 — 7,014 
Other16,036 6,958 3,507 8,128 2,232 
Total554,255 700,307 131,887 88,881 60,543 311,353 
Non-current accrued taxes (including unrecognized tax benefits)(229,784)63,121 (78,191)(284,571)(11,990)(42,417)
Accumulated deferred income taxes and taxes accrued($1,286,123)($2,138,522)($646,674)($338,714)($639,422)($359,835)
The Registrant Subsidiaries’ estimated tax attributes carryovers and their expiration dates as of December 31, 2021 are as follows:

 Entergy ArkansasEntergy LouisianaEntergy MississippiEntergy New OrleansEntergy TexasSystem Energy
       
Federal net operating losses before 1/1/2018$— billion$1.7 billion$— billion$0.9 billion$— billion$— billion
Year(s) of expirationN/A2035-2037N/A2037N/AN/A
Federal net operating losses - 1/1/2018 forward$4.5 billion$4.5 billion$2.1 billion$0.7 billion$2.6 billion$— billion
Year(s) of expirationN/AN/AN/AN/AN/AN/A
       
State net operating losses$4.8 billion$7.2 billion$2.3 billion$1.7 billion$— million$— million
Year(s) of expiration2023-2026N/A2038-2041N/AN/AN/A
       
Misc. federal credits$4.7 million$12.3 million$1.8 million$15.3 million$3.1 million$1.5 million
Year(s) of expiration2038-20412035-20412038-20412037-20412036-20412036-2041
       
State credits$— million$— million$1.3 million$—million$2.9 million$9 million
Year(s) of expirationN/AN/A2022-2025N/A20272022-2025

As a result of the accounting for uncertain tax positions, the amount of the deferred tax assets reflected in the financial statements is less than the amount of the tax effect of the federal and state net operating loss carryovers and tax credit carryovers.

Unrecognized tax benefits

Accounting standards establish a “more-likely-than-not” recognition threshold that must be met before a tax benefit can be recognized in the financial statements.  If a tax deduction is taken on a tax return but does not meet the more-likely-than-not recognition threshold, an increase in income tax liability, above what is payable on the tax return, is required to be recorded.  A reconciliation of Entergy’s beginning and ending amount of unrecognized tax benefits is as follows:
 202120202019
 (In Thousands)
Gross balance at January 1$5,699,339 $7,383,154 $7,181,482 
Additions based on tax positions related to the current year101,623 669,207 731,276 
Additions for tax positions of prior years33,419 98,591 151,628 
Reductions for tax positions of prior years (74,413)(935,735)(681,232)
Settlements— (1,515,878)— 
Gross balance at December 315,759,968 5,699,339 7,383,154 
Offsets to gross unrecognized tax benefits:   
Loss and tax credit carryovers(4,987,799)(4,710,214)(5,831,587)
Cash paid to taxing authorities(60,000)(10,000)(10,000)
Unrecognized tax benefits net of unused tax attributes, refund claims and payments (a)$712,169 $979,125 $1,541,567 
(a)Potential tax liability above what is payable on tax returns

The balances of unrecognized tax benefits include $2,256 million, $2,208 million, and $2,421 million as of December 31, 2021, 2020, and 2019, respectively, which, if recognized, would lower the effective income tax rates.  Because of the effect of deferred tax accounting, the remaining balances of unrecognized tax benefits of $3,504 million, $3,491 million, and $4,962 million as of December 31, 2021, 2020, and 2019, respectively, if disallowed, would not affect the annual effective income tax rate but would accelerate the payment of cash to the taxing authority to an earlier period.

Entergy accrues interest expense, if any, related to unrecognized tax benefits in income tax expense.  Entergy’s December 31, 2021, 2020, and 2019 accrued balance for the possible payment of interest is approximately $52 million, $44 million, and $48 million, respectively. Interest (net-of-tax) of $8 million, ($4) million, and $4 million was recorded in 2021, 2020, and 2019, respectively.

A reconciliation of the Registrant Subsidiaries’ beginning and ending amount of unrecognized tax benefits for 2021, 2020, and 2019 is as follows:
2021Entergy ArkansasEntergy LouisianaEntergy MississippiEntergy New OrleansEntergy TexasSystem Energy
 (In Thousands)
Gross balance at January 1, 2021$1,364,635 $640,295 $549,717 $639,546 $521,932 $21,652 
Additions based on tax positions related to the current year30,419 13,437 684 1,050 32,616 1,753 
Additions for tax positions of prior years15,013 9,304 1,504 2,315 1,897 
Reductions for tax positions of prior years(1,573)(58,408)(2,336)(1,105)(4,568)(1,946)
Gross balance at December 31, 20211,408,494 604,628 549,569 639,497 552,295 23,356 
Offsets to gross unrecognized tax benefits:      
Loss and tax credit carryovers(992,643)(604,628)(388,728)(484,899)(540,694)(8,576)
Unrecognized tax benefits net of unused tax attributes and payments$415,851 $— $160,841 $154,598 $11,601 $14,780 

2020Entergy ArkansasEntergy LouisianaEntergy MississippiEntergy New OrleansEntergy TexasSystem Energy
 (In Thousands)
Gross balance at January 1, 2020$1,341,242 $2,381,653 $566,287 $716,773 $21,406 $473,331 
Additions based on tax positions related to the current year (a)9,403 35,681 5,619 2,430 504,362 4,013 
Additions for tax positions of prior years13,400 10,508 1,156 294 799 4,606 
Reductions for tax positions of prior years(11,346)(679,601)(24,173)(80,267)(5,559)(41,466)
Settlements11,936 (1,107,946)828 316 924 (418,832)
Gross balance at December 31, 20201,364,635 640,295 549,717 639,546 521,932 21,652 
Offsets to gross unrecognized tax benefits:      
Loss and tax credit carryovers(1,112,628)(640,295)(465,679)(451,922)(507,720)(7,413)
Unrecognized tax benefits net of unused tax attributes and payments$252,007 $— $84,038 $187,624 $14,212 $14,239 
2019Entergy ArkansasEntergy LouisianaEntergy MississippiEntergy New OrleansEntergy TexasSystem Energy
 (In Thousands)
Gross balance at January 1, 2019$1,298,662 $2,400,171 $508,765 $686,687 $17,802 $467,487 
Additions based on tax positions related to the current year84,335 28,705 68,594 40,676 2,312 5,496 
Additions for tax positions of prior years20,399 25,090 1,651 489 1,299 2,186 
Reductions for tax positions of prior years(62,154)(72,313)(12,723)(11,079)(7)(1,838)
Gross balance at December 31, 20191,341,242 2,381,653 566,287 716,773 21,406 473,331 
Offsets to gross unrecognized tax benefits:      
Loss and tax credit carryovers(1,134,187)(1,573,257)(506,976)(445,430)(3,944)(8,392)
Unrecognized tax benefits net of unused tax attributes and payments$207,055 $808,396 $59,311 $271,343 $17,462 $464,939 

(a)The primary additions for Entergy Texas in 2020 are related to the mark-to-market treatment discussed in “Other Tax Matters - Tax Accounting Methods” below.

The Registrant Subsidiaries’ balances of unrecognized tax benefits included amounts which, if recognized, would have reduced income tax expense as follows:
December 31,
 202120202019
 (In Millions)
Entergy Arkansas$262.1 $259.3 $203.3 
Entergy Louisiana$66.3 $63.8 $556.3 
Entergy Mississippi$51.7 $50.7 $1.9 
Entergy New Orleans$228.6 $203.5 $242.7 
Entergy Texas$2.6 $6.1 $5.7 
System Energy$1.7 $0.5 $— 

Accrued balances for the possible payment of interest related to unrecognized tax benefits are as follows:
December 31,
 202120202019
 (In Millions)
Entergy Arkansas$2.7 $2.3 $3.1 
Entergy Louisiana$3.7 $3.4 $14.2 
Entergy Mississippi$2.4 $1.9 $1.7 
Entergy New Orleans$5.2 $3.9 $4.7 
Entergy Texas$1.1 $0.9 $1.1 
System Energy$12.1 $11.9 $14.5 
The Registrant Subsidiaries record interest and penalties related to unrecognized tax benefits in income tax expense.  No penalties were recorded in 2021, 2020, and 2019. Interest (net-of-tax) was recorded as follows:
202120202019
(In Millions)
Entergy Arkansas$0.4 ($0.8)$1.4 
Entergy Louisiana$0.3 ($10.8)($3.7)
Entergy Mississippi$0.5 $0.2 $0.5 
Entergy New Orleans$1.3 ($0.8)$2.0 
Entergy Texas$0.2 ($0.2)$0.2 
System Energy$0.2 ($2.6)$1.3 

Income Tax Audits

Entergy and its subsidiaries file U.S. federal and various state income tax returns.  IRS examinations are complete for years before 2016. All state taxing authorities’ examinations are complete for years before 2014. Entergy regularly defends its positions and works with the IRS to resolve audits.  The resolution of audit issues could result in significant changes to the amounts of unrecognized tax benefits in the next twelve months.

2014-2015 IRS Audit

The IRS completed its examination of the 2014 and 2015 tax years and issued its 2014-2015 RAR in November 2020. Entergy agreed to all proposed adjustments contained in the RAR. Entergy and the Registrant Subsidiaries recorded the effects of the adjustments associated with the audit in 2020.

In October 2015 two of Entergy’s Louisiana utilities, Entergy Gulf States Louisiana and Entergy Louisiana, combined their businesses into a legal entity which is identified as Entergy Louisiana herein. The structure of the business combination required Entergy to recognize a gain for income tax purposes which resulted in an increase in the tax basis of the assets for Entergy Louisiana. This resulted in recognition in 2015 of a $334 million permanent difference and income tax benefit, net of the uncertain tax position recorded on the transaction.

Primarily related to resolution of the business combination issues, completion of the 2014-2015 IRS audit in 2020 resulted in a $230 million reduction to deferred income tax expense for Entergy. This reduction to deferred income tax expense includes: Entergy Louisiana reversing its provision for uncertain tax position with respect to the business combination, which resulted in a reduction to deferred income tax expense of $383 million; Entergy Corporation recording an increase to deferred tax expense of $61 million and Entergy Wholesale Commodities recording an increase to deferred tax expense of $105 million from the re-measurement of deferred tax assets associated with the resolved uncertain tax position; and miscellaneous other individually insignificant benefits totaling $13 million.

The completion of the 2014-2015 tax audit also resulted in a $31 million reduction to income tax expense associated with Entergy Louisiana’s method of accounting related to the adoption of tangible property regulations. As a result of the settlement of the tangible property regulation tax position, Entergy Louisiana was required to record a $33 million ($24 million net-of-tax) regulatory charge and a corresponding regulatory liability to reflect its obligation to customers pursuant to a prior regulatory settlement.

Finally, upon completion of the 2014-2015 tax audit, Entergy New Orleans recorded a reduction to income tax expense of $8 million associated with claims for mark-to-market deductions.

In the first quarter 2020, Entergy and the IRS agreed on the treatment of funds received by Entergy Louisiana in conjunction with the Act 55 financing of Hurricane Isaac storm costs, which resulted in a net reduction
of income tax expense of approximately $32 million. As a result of the settlement, the position was partially sustained, and Entergy Louisiana recorded a reduction of income tax expense of approximately $58 million primarily due to the reversal of a provision for uncertain tax positions in excess of the agreed-upon settlement. As a result of the IRS settlement, Entergy Louisiana recorded a $29 million ($21 million net-of-tax) regulatory charge and a corresponding regulatory liability to reflect its obligation to customers pursuant to the LPSC Hurricane Isaac Act 55 financing order.

Additional effects of the completion of the 2014-2015 IRS tax audit are discussed below within Tax Accounting Methods.

Other Tax Matters

Tax Cuts and Jobs Act (TCJA)

The most significant effect of the TCJA for Entergy and the Registrant Subsidiaries was the change in the federal corporate income tax rate from 35% to 21%, effective January 1, 2018.

TCJA also limited the deduction for net business interest expense to 30 percent of adjusted taxable income, which is similar to earnings before interest, taxes, depreciation, and amortization. The limitation does not apply to interest expense that is properly allocable to a trade or business classified as a regulated public utility. This was further modified by a temporary provision of the CARES Act resulting in an increase of the adjusted taxable income limitation from 30% to 50% for tax years that begin in 2019 or 2020.

The IRS issued final regulations which are effective for Entergy beginning with the 2021 tax year. The regulations provide that if 90% of a tax group’s consolidated assets consist of regulated utility property, the entire consolidated tax group will be treated as a regulated public utility and all of the consolidated group’s interest expense will be currently tax deductible. Entergy expects that this provision will continue to apply to Entergy’s business operations making the application of this limitation to Entergy less likely. The provision has not resulted in Entergy having to report any significant business interest expense limitations on its tax returns.

With respect to the federal corporate income tax rate change from 35% to 21% in 2017, Entergy and the Registrant Subsidiaries recorded a regulatory liability associated with the decrease in the net accumulated deferred income tax liability, which is often referred to as “excess ADIT,” a significant portion of which has been paid to customers in 2019, 2020 and 2021 in the form of lower rates. Entergy’s December 31, 2021 and December 31, 2020 balance sheets reflect a regulatory liability of $1.3 billion and $1.6 billion, respectively, as a result of the re-measurement of deferred tax assets and liabilities from the income tax rate change, amortization of excess ADIT, and payments to customers during 2019, 2020 and 2021. Entergy’s regulatory liability for income taxes includes a gross-up at the applicable tax rate because of the effect that excess ADIT has on the ratemaking formula. The regulatory liability for income taxes includes the effect of a) the reduction of the net deferred tax liability resulting in excess ADIT, and b) the tax gross-up of excess ADIT. The Registrant Subsidiaries’ December 31, 2021 and December 31, 2020 balance sheets reflect net regulatory liabilities for income taxes as follows:
20212020
(In Millions)
Entergy Arkansas$432 $467 
Entergy Louisiana$338 $479 
Entergy Mississippi$212 $224 
Entergy New Orleans$42 $59 
Entergy Texas$171 $205 
System Energy$113 $152 
Excess ADIT is generally classified into two categories: 1) the portion that is subject to the normalization requirements of the TCJA, i.e., “protected”, and 2) the portion that is not subject to such normalization provisions, referred to as “unprotected”. The TCJA provides that the normalization method of accounting for income taxes is required for excess ADIT associated with public utility property. The TCJA provides for the use of the average rate assumption method (ARAM) for the determination of the timing of the return of excess ADIT associated with such property. Under ARAM, the excess ADIT is reduced over the remaining life of the asset. Remaining asset lives vary for each Registrant Subsidiary, but the average life of public utility property is typically 30 years or longer. Entergy will amortize the protected portion of the excess ADIT in conformity with the normalization requirements. The Registrant Subsidiaries’ net regulatory liability for income taxes as of December 31, 2021 and December 31, 2020, includes protected excess ADIT as follows:
20212020
(In Millions)
Entergy Arkansas$463 $490 
Entergy Louisiana$669 $721 
Entergy Mississippi$237 $248 
Entergy New Orleans$56 $61 
Entergy Texas$208 $215 
System Energy$148 $173 

Payment of the unprotected excess accumulated deferred income taxes results in a reduction in the regulatory liability for income taxes and a corresponding reduction in income tax expense. This has a significant effect on the effective tax rate for the period as compared to the statutory tax rate. The Registrant Subsidiaries’ net regulatory liability for income taxes as of December 31, 2021 and December 31, 2020, includes unprotected excess ADIT as follows:
20212020
(In Millions)
Entergy Arkansas$12 $11 
Entergy Louisiana$148 $223 
Entergy New Orleans$— $3 
Entergy Texas$26 $54 
System Energy$— $16 

The return of unprotected excess accumulated deferred income taxes reduced Entergy’s and the Registrant Subsidiaries’ regulatory liability for income taxes as follows for 2021 and 2020:
20212020
(In Millions)
Entergy$88 $74 
Entergy Arkansas$8 $8 
Entergy Louisiana$33 $31 
Entergy New Orleans$1 $6 
Entergy Texas$28 $29 
System Energy$18 $— 

In addition to the protected and unprotected excess ADIT amounts, the net regulatory liability for income taxes includes other regulatory assets and liabilities for income taxes associated with AFUDC, which is described in Note 1 to the financial statements.
Included in the effect of the computation of the changes in deferred tax assets and liabilities is the recognition threshold and measurement of uncertain tax positions resulting in unrecognized tax benefits. The final economic outcome of such unrecognized tax benefits is generally the result of a negotiated settlement with the IRS that often differs from the amount that is recorded as realizable under GAAP. The intrinsic uncertainty with respect to all such tax positions means that the difference between current estimates of such amounts likely to be realized and actual amounts realized upon settlement may have an effect on income tax expense and the regulatory liability for income taxes in future periods.

Entergy anticipates that the effect of TCJA may continue to have ramifications that require adjustments in the future as certain events occur. These events include: 1) IRS audit adjustments to or amendments of federal and state income tax returns that include modifications to the computation of taxable income resulting from TCJA; and 2) additional guidance, interpretations, or rulings by the U.S. Department of the Treasury or the IRS. The potential exists for these types of events to result in future tax expense adjustments because of the difference in the federal corporate income tax rate between past and future periods and the effect of the tax rate change on ratemaking. In turn, these events also could potentially affect the regulatory liability for income taxes.

Coronavirus Aid, Relief, and Economic Security Act

In response to the economic impacts of the COVID-19 pandemic, President Trump signed the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) into law on March 27, 2020. The CARES Act provisions that result in the most significant opportunities for tax relief to Entergy and the Registrant Subsidiaries are (i) permitting a five-year carryback of 2018-2020 NOLs, (ii) removing the 80 percent limitation on NOLs carried to tax years beginning before 2021, (iii) increasing the limitation on interest expense deductibility for 2019 and 2020, (iv) accelerating available refunds for minimum tax credit carryforwards, modifying limitations on charitable contributions during 2020, and (v) delaying the payment of employer payroll taxes. Entergy deferred approximately $64 million of 2020 payroll tax payments, payable in equal installments over two years. The initial installment of $32 million was paid in December 2021. The second installment will be paid in December 2022.

Entergy Wholesale Commodities Restructuring

In the fourth quarter 2019, two separate events occurred resulting in a reduction of tax expense of $174 million. In November 2019 an Entergy Wholesale Commodities subsidiary recognized a reduction in income tax expense of $18 million in connection with the accounting method on power contracts associated with the Palisades nuclear power station. Additionally, Entergy’s ownership of Indian Point 2 and Indian Point 3 was restructured. The restructuring required Entergy to recognize Indian Point 2 and Indian Point 3 nuclear decommissioning liabilities for income tax purposes resulting in a tax accounting permanent difference that reduced income tax expense, net of unrecognized tax benefits, by $156 million. The accrual of the nuclear decommissioning liabilities also required Entergy to recognize a gain for income tax purposes, a portion of which resulted in an increase in the tax basis of the assets. Recognition of the gain and the increase in the tax basis of the assets represents a tax accounting temporary difference.

Immediately prior to the restructuring, through its ownership of Indian Point 2 and Indian Point 3, Entergy donated property to Stony Brook University and recognized an associated tax deduction resulting in a decrease to tax expense of $19 million.

In the fourth quarter 2020, Entergy’s ownership of Palisades was restructured. The restructuring required Entergy to recognize Palisades’ nuclear decommissioning liability for income tax purposes resulting in a tax accounting permanent difference that reduced income tax expense, net of unrecognized tax benefits, by $9.2 million. The accrual of the nuclear decommissioning liability also required Entergy to recognize a gain for income tax purposes, a portion of which resulted in an increase in the tax basis of the assets. Recognition of the gain and the increase in the tax basis of the assets represents a tax accounting temporary difference.
Tax Accounting Methods

In the fourth quarter 2015, System Energy and Entergy Louisiana adopted a new method of accounting for income tax return purposes in which their nuclear decommissioning costs will be treated as production costs of electricity includable in cost of goods sold. The new method resulted in a reduction of taxable income of $1.2 billion for System Energy and $2.2 billion for Energy Louisiana.

In conjunction with the 2014-2015 IRS audit discussed above, the IRS issued proposed adjustments concerning the nuclear decommissioning tax position allowing System Energy to include $102 million of its decommissioning liability in cost of goods sold, and Entergy Louisiana to include $221 million of its decommissioning liability in cost of goods sold. Entergy, System Energy, and Entergy Louisiana agreed to the proposed adjustments included in the RAR.

As a result of System Energy being allowed to include part of its decommissioning liability in cost of goods sold, System Energy and Entergy recorded a deferred tax liability of $26 million. System Energy also recorded federal and state taxes payable of $402 million. However, on a consolidated basis, Entergy utilized tax loss carryovers to offset the federal taxable income adjustment and did not record federal taxes payable as a result of the outcome of this uncertain tax position.

As a result of Entergy Louisiana being allowed to include part of its decommissioning liability in cost of goods sold, Entergy Louisiana and Entergy recorded a deferred tax liability of $60 million. Both Entergy Louisiana and Entergy utilized tax loss carryovers to offset the taxable income adjustment and accordingly did not record taxes payable as a result of the outcome of this uncertain tax position.

The partial disallowance of this uncertain tax position to include the decommissioning liability in cost of goods sold resulted in a $1.5 billion decrease in the balance of unrecognized tax benefits related to federal and state taxes for Entergy. Additionally, both System Energy and Entergy Louisiana recorded a reduction to their balances of unrecognized tax benefits for federal and state taxes of $461 million and $1.1 billion, respectively.

Entergy Arkansas adopted the same method of accounting for its nuclear decommissioning costs which resulted in a $1.8 billion reduction in taxable income on its 2018 tax return.

In 2016, Entergy Louisiana elected mark-to-market income tax treatment for various wholesale electric power purchase and sale agreements, including Entergy Louisiana’s contract to purchase electricity from the Vidalia hydroelectric facility and from System Energy under the Unit Power Sales Agreement. The election resulted in a $2.2 billion deductible temporary difference. In 2017, Entergy New Orleans also elected mark-to-market income tax treatment for wholesale electric contracts which resulted in a $1.1 billion deductible temporary difference. In 2018, Entergy Arkansas and Entergy Mississippi accrued deductible temporary differences related to mark-to-market tax accounting for wholesale electric contracts of $2.1 billion and $1.9 billion, respectively. Additionally, in 2020, Entergy Texas elected mark-to-market income tax treatment for wholesale electric power purchase and sale agreements which resulted in a $2.5 billion deductible temporary difference.

Arkansas and Louisiana Corporate Income Tax Rate Changes

In April 2019 and December 2021 the State of Arkansas enacted corporate income tax law changes that phased in rate reductions from the former rate of 6.5% to 6.2% in 2021, 5.9% in 2022, and 5.7% in 2023.    As a result of the 2019 rate reduction, Entergy Arkansas computed a regulatory liability for income taxes as of December 31, 2020 of approximately $21 million, which includes a tax gross-up related to the treatment of income taxes in the retail and wholesale ratemaking formulas and has been included in the appropriate rate mechanisms. Entergy Arkansas recorded an incremental regulatory liability of $11 million associated with the rate reduction enacted in December 2021. The Arkansas tax law enactment also phases in an increase to the net operating loss carryover period from five to ten years.
Pursuant to legislation enacted in 2021 and approved by Louisiana citizens by amendment to the state constitution, beginning January 1, 2022, federal income taxes paid will no longer be deductible for state income tax purposes, and the top Louisiana corporate income tax rate will be reduced from 8% to 7.5%. As a result of this change in Louisiana tax law, the Louisiana applicable tax rate increased by 0.85%. Accordingly, deferred tax assets and liabilities were adjusted to reflect the new applicable federal and state rates. Legislation enacted in 2021 also provides that Louisiana net operating losses generally have an indefinite carryover period.

Entergy recorded a net increase to its deferred tax asset of $27 million. Entergy Louisiana and Entergy New Orleans recorded net increases to their deferred tax liabilities before consideration of the tax gross-up of $77 million and $8 million, respectively, which were offset by regulatory assets for income taxes. Therefore, these increases had no effect on tax expense. However, the increase of deferred tax assets associated with certain assets reduced tax expense for Entergy Louisiana and Entergy New Orleans by $6 million and $2 million, respectively.

Consolidated Income Tax Return of Entergy Corporation

In September 2019, Entergy Utility Holding Company, LLC and its regulated, wholly-owned subsidiaries including Entergy Arkansas, Entergy Louisiana, Entergy Mississippi, and Entergy New Orleans, became eligible to and joined the Entergy Corporation consolidated federal income tax group.  As a result of these four Utility operating companies re-joining the Entergy Corporation consolidated tax return group, Entergy was able to recognize a $41 million deferred tax asset associated with a previously unrecognized net operating loss carryover.

In September 2019, Entergy Texas issued $35 million of 5.375% Series A preferred stock with a liquidation value of $25 per share resulting in the disaffiliation and de-consolidation of Entergy Texas from the consolidated federal income tax return of Entergy Corporation.  These changes will not affect the accrual or allocation of income taxes for the Registrant Subsidiaries. See Note 6 to the financial statements for discussion of the preferred stock issuance.

Vermont Yankee

The Vermont Yankee transaction resulted in Entergy generating a net deferred tax asset in January 2019.  The deferred tax asset could not be fully realized by Entergy in the first quarter 2019; accordingly, Entergy accrued a net tax expense of $29 million on the disposition of Vermont Yankee. See Note 14 to the financial statements for discussion of the Vermont Yankee transaction.

Stock Compensation

In accordance with stock compensation accounting rules, Entergy and the Registrant Subsidiaries recognized excess tax deductions as a reduction of income tax expense in the first quarter 2020. Due to the vesting and exercise of certain Entergy stock-based awards, Entergy recorded a permanent tax reduction of approximately $24.7 million, including $4.8 million for Entergy Arkansas, $8.6 million for Entergy Louisiana, $2.7 million for Entergy Mississippi, $1.5 million for Entergy New Orleans, $2.7 million for Entergy Texas, and $1.3 million for System Energy.
Entergy Texas [Member]  
Income Taxes INCOME TAXES (Entergy Corporation, Entergy Arkansas, Entergy Louisiana, Entergy Mississippi, Entergy New Orleans, Entergy Texas, and System Energy)
Income taxes for 2021, 2020, and 2019 for Entergy Corporation and Subsidiaries consist of the following:
 202120202019
 (In Thousands)
Current:   
Federal($5,003)$5,807 ($14,416)
State(8,995)57,939 6,535 
Total(13,998)63,746 (7,881)
Deferred and non-current - net205,891 (190,635)(155,956)
Investment tax credit adjustments - net(519)5,383 (5,988)
Income taxes$191,374 ($121,506)($169,825)

Income taxes for 2021, 2020, and 2019 for Entergy’s Registrant Subsidiaries consist of the following:
2021Entergy ArkansasEntergy LouisianaEntergy MississippiEntergy New OrleansEntergy TexasSystem Energy
(In Thousands)
Current:      
Federal($20,285)($24,053)($5,868)($6,724)($189)$29,416 
State529 2,459 (11,506)(413)1,261 (10,258)
Total(19,756)(21,594)(17,374)(7,137)1,072 19,158 
Deferred and non-current - net96,180 146,786 60,861 12,870 25,087 (25,229)
Investment tax credit adjustments - net(1,229)(4,783)1,836 203 (633)4,094 
Income taxes$75,195 $120,409 $45,323 $5,936 $25,526 ($1,977)

2020Entergy ArkansasEntergy LouisianaEntergy MississippiEntergy New OrleansEntergy TexasSystem Energy
 (In Thousands)
Current:      
Federal($44,627)$62,728 ($14,580)$293 ($5,603)$372,206 
State(2,563)4,457 (1,316)(303)2,658 55,551 
Total(47,190)67,185 (15,896)(10)(2,945)427,757 
Deferred and non-current - net96,195 (444,647)43,640 (18,153)6,619 (405,928)
Investment tax credit adjustments - net(1,228)(4,862)(554)13,956 (632)(1,286)
Income taxes$47,777 ($382,324)$27,190 ($4,207)$3,042 $20,543 
2019Entergy ArkansasEntergy LouisianaEntergy MississippiEntergy New OrleansEntergy TexasSystem Energy
 (In Thousands)
Current:      
Federal($14,549)($20,173)($8,939)($5,822)$16,035 $16,256 
State(714)(735)5,823 1,856 663 (2,831)
Total(15,263)(20,908)(3,116)(3,966)16,698 13,425 
Deferred and non-current - net(30,278)147,453 34,579 4,248 (69,963)422 
Investment tax credit adjustments - net(1,228)(4,922)(597)(96)(631)1,502 
Income taxes($46,769)$121,623 $30,866 $186 ($53,896)$15,349 

Total income taxes for Entergy Corporation and Subsidiaries differ from the amounts computed by applying the statutory income tax rate to income before income taxes.  The reasons for the differences for the years 2021, 2020, and 2019 are:
 202120202019
 (In Thousands)
Net income attributable to Entergy Corporation$1,118,492 $1,388,334 $1,241,226 
Preferred dividend requirements of subsidiaries227 18,319 17,018 
Consolidated net income1,118,719 1,406,653 1,258,244 
Income taxes191,374 (121,506)(169,825)
Income before income taxes$1,310,093 $1,285,147 $1,088,419 
Computed at statutory rate (21%)$275,120 $269,881 $228,568 
Increases (reductions) in tax resulting from:   
State income taxes net of federal income tax effect79,273 60,087 61,791 
Regulatory differences - utility plant items(57,556)(53,229)(45,336)
Equity component of AFUDC(14,799)(25,080)(30,444)
Amortization of investment tax credits(7,695)(8,386)(8,093)
Flow-through / permanent differences(5,585)11,099 (2,059)
Amortization of excess ADIT (a)(66,478)(59,629)(205,614)
Arkansas and Louisiana Rate Changes (b)(27,108)— — 
IRS audit adjustment (d)— (301,041)— 
Entergy Wholesale Commodities restructuring (c)— (9,223)(173,725)
Stock compensation (e)— (25,591)— 
Charitable contribution (c)— — (19,101)
Net operating loss recognition— — (41,427)
Provision for uncertain tax positions16,533 15,208 7,332 
Valuation allowance(2,600)— 59,345 
Other - net2,269 4,398 (1,062)
Total income taxes as reported$191,374 ($121,506)($169,825)
Effective Income Tax Rate14.6 %(9.5 %)(15.6 %)

(a)See “Other Tax Matters - Tax Cuts and Jobs Act” below for discussion of the amortization of excess accumulated deferred income taxes (ADIT) in 2019, 2020, and 2021 and the tax legislation enactment in 2017.
(b)See “Arkansas and Louisiana Corporate Income Tax Rate Changes” below for details.
(c)See Other Tax Matters - Entergy Wholesale Commodities Restructuring” below for discussion of the Entergy Wholesale Commodities restructuring in 2019, the ownership of Palisades restructuring in 2020, and the charitable contribution in 2019.
(d)See “Income Tax Audits - 2014-2015 IRS Audit” below for discussion of the resolution of the audit in 2020.
(e)See “Other Tax Matters - Stock Compensation” below for discussion of excess tax deductions.

Total income taxes for the Registrant Subsidiaries differ from the amounts computed by applying the statutory income tax rate to income before taxes.  The reasons for the differences for the years 2021, 2020, and 2019 are:
2021Entergy ArkansasEntergy LouisianaEntergy MississippiEntergy New OrleansEntergy TexasSystem Energy
 (In Thousands)
Net income$298,484 $653,984 $166,834 $31,798 $228,824 $106,814 
Income taxes75,195 120,409 45,323 5,936 25,526 (1,977)
Pretax income$373,679 $774,393 $212,157 $37,734 $254,350 $104,837 
Computed at statutory rate (21%)$78,473 $162,623 $44,553 $7,924 $53,413 $22,016 
Increases (reductions) in tax resulting from:     
State income taxes net of federal income tax effect19,633 41,030 9,305 2,579 1,553 5,385 
Regulatory differences - utility plant items(16,078)(14,123)(8,133)(4,332)(2,115)(12,776)
Equity component of AFUDC(3,207)(6,016)(1,701)(498)(2,077)(1,300)
Amortization of investment tax credits(1,201)(4,729)64 (56)(617)(1,155)
Flow-through / permanent differences(814)(2,655)124 1,559 (475)(1,235)
Amortization of excess ADIT (a)(5,845)(24,323)— (1,028)(21,929)(13,354)
Arkansas and Louisiana Rate Changes (b)398 (6,126)395 (1,569)216 115 
Non-taxable dividend income— (26,801)— — — — 
Provision for uncertain tax positions353 300 465 1,200 (2,716)200 
Valuation Allowance2,766 — — — — — 
Other - net717 1,229 251 157 273 127 
Total income taxes as reported$75,195 $120,409 $45,323 $5,936 $25,526 ($1,977)
Effective Income Tax Rate20.1 %15.5 %21.4 %15.7 %10.0 %(1.9 %)
2020Entergy ArkansasEntergy LouisianaEntergy MississippiEntergy New OrleansEntergy TexasSystem Energy
 (In Thousands)
Net income$245,232 $1,082,352 $140,583 $49,338 $215,073 $99,131 
Income taxes47,777 (382,324)27,190 (4,207)3,042 20,543 
Pretax income$293,009 $700,028 $167,773 $45,131 $218,115 $119,674 
Computed at statutory rate (21%)$61,532 $147,006 $35,232 $9,478 $45,804 $25,132 
Increases (reductions) in tax resulting from:
State income taxes net of federal income tax effect16,256 38,182 6,917 2,606 1,460 5,524 
Regulatory differences - utility plant items(8,034)(23,819)(7,441)(3,442)(7,673)(2,821)
Equity component of AFUDC(3,154)(8,012)(1,412)(1,331)(9,255)(1,916)
Amortization of investment tax credits(1,201)(4,811)(540)(61)(617)(1,155)
Flow-through / permanent differences(2,219)1,404 (102)498 766 (421)
Amortization of excess ADIT (a)(6,011)(26,293)18 (4,564)(22,780)— 
Stock compensation (d)(4,952)(9,004)(2,763)(1,526)(2,842)(1,300)
IRS audit adjustment (c)(6,351)(471,702)(3,768)(6,819)(2,091)(2,925)
Non-taxable dividend income— (26,795)— — — — 
Provision for uncertain tax positions1,200 300 800 800 — 300 
Other - net711 1,220 249 154 270 125 
Total income taxes as reported$47,777 ($382,324)$27,190 ($4,207)$3,042 $20,543 
Effective Income Tax Rate16.3 %(54.6 %)16.2 %(9.3 %)1.4 %17.2 %

2019Entergy ArkansasEntergy LouisianaEntergy MississippiEntergy New OrleansEntergy TexasSystem Energy
 (In Thousands)
Net income$262,964 $691,537 $119,925 $52,629 $159,397 $99,120 
Income taxes(46,769)121,623 30,866 186 (53,896)15,349 
Pretax income$216,195 $813,160 $150,791 $52,815 $105,501 $114,469 
Computed at statutory rate (21%)$45,401 $170,764 $31,666 $11,091 $22,155 $24,039 
Increases (reductions) in tax resulting from:      
State income taxes net of federal income tax effect15,954 42,854 5,563 3,443 360 5,134 
Regulatory differences - utility plant items(10,627)(19,421)(5,556)(1,532)(1,987)(6,213)
Equity component of AFUDC(3,255)(15,545)(1,755)(2,088)(5,973)(1,829)
Amortization of investment tax credits(1,201)(4,871)(160)(88)(617)(1,155)
Flow-through / permanent differences696 439 160 (741)560 (500)
Amortization of excess ADIT (a)(90,921)(28,531)203 (11,724)(69,091)(5,550)
Non-taxable dividend income— (26,795)— — — — 
Provision for uncertain tax positions(3,517)1,519 500 1,672 430 1,300 
Other - net701 1,210 245 153 267 123 
Total income taxes as reported($46,769)$121,623 $30,866 $186 ($53,896)$15,349 
Effective Income Tax Rate(21.6 %)15.0 %20.5 %0.4 %(51.1 %)13.4 %
(a)See “Other Tax Matters - Tax Cuts and Jobs Act” below for discussion of the amortization of excess accumulated deferred income taxes (ADIT) in 2019, 2020 and 2021 and the tax legislation enactment in 2017.
(b)See “Arkansas and Louisiana Corporate Income Tax Rate Changes” below for details.
(c)See “Income Tax Audits - 2014-2015 IRS Audit” below for discussion of the resolution of the audit in 2020.
(d)See “Other Tax Matters - Stock Compensation” below for discussion of excess tax deductions.


Significant components of accumulated deferred income taxes and taxes accrued for Entergy Corporation and Subsidiaries as of December 31, 2021 and 2020 are as follows:
 
 20212020
 (In Thousands)
Deferred tax liabilities:  
Plant basis differences - net($6,136,563)($4,795,422)
Regulatory assets(930,244)(429,996)
Nuclear decommissioning trusts/receivables(656,185)(1,188,235)
Pension, net regulatory asset(322,788)(327,445)
Combined unitary state taxes(7,255)(7,723)
Unbilled/deferred revenues— (9,152)
Accumulated storm damage provision(207,243)— 
Deferred fuel(85,310)(7,667)
Other(341,450)(549,355)
Total(8,687,038)(7,314,995)
Deferred tax assets:  
Nuclear decommissioning liabilities278,136 968,464 
Regulatory liabilities1,318,381 791,927 
Pension and other post-employment benefits208,128 278,486 
Sale and leaseback102,474 102,477 
Compensation79,798 89,279 
Accumulated deferred investment tax credit57,986 57,379 
Provision for allowances and contingencies82,286 71,598 
Power purchase agreements55,259 352,019 
Unbilled/deferred revenues26,683 — 
Net operating loss carryforwards2,868,424 1,580,109 
Capital losses and miscellaneous tax credits11,111 21,291 
Valuation allowance(325,239)(328,581)
Other200,032 230,291 
Total4,963,459 4,214,739 
Non-current accrued taxes (including unrecognized tax benefits)(929,032)(1,185,227)
Accumulated deferred income taxes and taxes accrued($4,652,611)($4,285,483)
Entergy’s estimated tax attributes carryovers and their expiration dates as of December 31, 2021 are as follows:
Carryover DescriptionCarryover AmountYear(s) of expiration
   
Federal net operating losses before 1/1/2018$6.2 billion2023-2027
Federal net operating losses - 1/1/2018 forward$21.1 billionN/A
State net operating losses$7.4 billion2022-2041
State net operating losses with no expiration$16.7 billionN/A
Federal and state charitable contributions$460.8 million2022-2026
Miscellaneous federal and state credits$73.1 million2022-2041

As a result of the accounting for uncertain tax positions, the amount of the deferred tax assets reflected in the financial statements is less than the amount of the tax effect of the federal and state net operating loss carryovers, tax credit carryovers, and other tax attributes reflected on income tax returns. Entergy evaluates the available positive and negative evidence to estimate whether sufficient future taxable income of the appropriate character will be generated to realize the benefits of existing deferred tax assets. When the evaluation indicates that Entergy will not be able to realize the existing benefits, a valuation allowance is recorded to reduce deferred tax assets to the realizable amount.

Because it is more likely than not that the benefits from certain state net operating losses and other deferred tax assets will not be utilized, valuation allowances totaling $325 million as of December 31, 2021 and $329 million as of December 31, 2020 have been provided on the deferred tax assets related to federal and state jurisdictions in which Entergy does not currently expect to be able to utilize certain separate company tax return attributes, preventing realization of such deferred tax assets. As a result of incurring costs related to Hurricane Ida restoration, certain Utility operating companies are entitled to an accelerated tax deduction which generated a taxable loss in various taxing jurisdictions. This accelerated deduction has impaired the realizability of a limited term carryover tax attribute. Accordingly, the impairment contributed to the activity reflected for the valuation allowance disclosed above.
Significant components of accumulated deferred income taxes and taxes accrued for the Registrant Subsidiaries as of December 31, 2021 and 2020 are as follows:
2021Entergy ArkansasEntergy LouisianaEntergy MississippiEntergy New OrleansEntergy TexasSystem Energy
 (In Thousands)
Deferred tax liabilities:      
Plant basis differences - net($1,158,523)($3,429,473)($681,968)($192,660)($654,252)($433,874)
Regulatory assets(226,687)(530,274)(34,799)(30,694)(45,470)(61,205)
Nuclear decommissioning trusts/receivables(175,882)(186,382)— — — (153,610)
Pension, net regulatory asset(92,881)(93,681)(22,253)(11,429)(19,914)(18,033)
Deferred fuel(27,497)(13,686)(30,409)(1,600)(10,139)(49)
Accumulated storm damage provision— (193,967)— — (13,276)— 
Other(77,820)(138,299)(29,108)(33,071)(2,526)(5,622)
Total(1,759,290)(4,585,762)(798,537)(269,454)(745,577)(672,393)
Deferred tax assets:      
Regulatory liabilities310,256 634,184 59,418 36,057 55,022 224,036 
Nuclear decommissioning liabilities123,568 (909)(433)94 9,432 
Pension and other post-employment benefits(26,577)73,006 (7,793)(16,090)(18,793)(1,925)
Sale and leaseback— — — — — 102,474 
Accumulated deferred investment tax credit7,518 30,666 2,723 4,391 1,958 10,729 
Provision for allowances and contingencies24,829 21,768 10,236 5,559 7,730 — 
Power purchase agreements— — 1,140 — (1,202)— 
Unbilled/deferred revenues3,331 9,919 2,306 971 10,196 — 
Compensation3,347 5,288 2,181 1,036 1,618 447 
Net operating loss carryforwards275,054 1,228,547 166,008 105,549 81 — 
Capital losses and miscellaneous tax credits— 5,141 1,258 10,977 883 1,958 
Other19,397 5,968 2,891 7,788 863 
Total740,723 2,013,578 240,369 155,805 58,450 347,153 
Non-current accrued taxes (including unrecognized tax benefits)(397,634)138,330 (161,929)(251,735)(5,369)(57,691)
Accumulated deferred income taxes and taxes accrued($1,416,201)($2,433,854)($720,097)($365,384)($692,496)($382,931)
2020Entergy ArkansasEntergy LouisianaEntergy MississippiEntergy New OrleansEntergy TexasSystem Energy
 (In Thousands)
Deferred tax liabilities:      
Plant basis differences - net($1,117,948)($2,481,976)($623,796)($83,457)($620,669)($407,125)
Regulatory assets(188,284)(95,135)(22,381)(20,276)(47,684)(56,496)
Nuclear decommissioning trusts/receivables(156,123)(148,040)— — — (131,985)
Pension, net funding(93,486)(95,854)(24,922)(11,564)(19,481)(20,330)
Deferred fuel— (4,210)(1,706)(1,393)— (314)
Other(54,753)(76,735)(27,565)(26,334)(141)(12,521)
Total(1,610,594)(2,901,950)(700,370)(143,024)(687,975)(628,771)
Deferred tax assets:      
Regulatory liabilities273,774 218,278 56,022 31,248 47,991 163,534 
Nuclear decommissioning liabilities123,319 7,767 — (419)121 29,916 
Pension and other post-employment benefits(24,747)72,724 (6,763)(13,997)(17,132)(1,344)
Sale and leaseback— — — — — 102,477 
Accumulated deferred investment tax credit7,971 31,155 2,261 4,197 2,088 9,706 
Provision for allowances and contingencies22,179 7,071 16,799 24,529 (4,094)— 
Power purchase agreements9,662 3,381 1,140 (5,324)(30,932)— 
Unbilled/deferred revenues4,242 (23,382)2,989 877 5,909 — 
Compensation2,264 3,240 1,670 761 1,308 48 
Net operating loss carryforwards119,555 363,806 54,262 26,564 53,052 — 
Capital losses and miscellaneous tax credits— 9,309 — 12,317 — 7,014 
Other16,036 6,958 3,507 8,128 2,232 
Total554,255 700,307 131,887 88,881 60,543 311,353 
Non-current accrued taxes (including unrecognized tax benefits)(229,784)63,121 (78,191)(284,571)(11,990)(42,417)
Accumulated deferred income taxes and taxes accrued($1,286,123)($2,138,522)($646,674)($338,714)($639,422)($359,835)
The Registrant Subsidiaries’ estimated tax attributes carryovers and their expiration dates as of December 31, 2021 are as follows:

 Entergy ArkansasEntergy LouisianaEntergy MississippiEntergy New OrleansEntergy TexasSystem Energy
       
Federal net operating losses before 1/1/2018$— billion$1.7 billion$— billion$0.9 billion$— billion$— billion
Year(s) of expirationN/A2035-2037N/A2037N/AN/A
Federal net operating losses - 1/1/2018 forward$4.5 billion$4.5 billion$2.1 billion$0.7 billion$2.6 billion$— billion
Year(s) of expirationN/AN/AN/AN/AN/AN/A
       
State net operating losses$4.8 billion$7.2 billion$2.3 billion$1.7 billion$— million$— million
Year(s) of expiration2023-2026N/A2038-2041N/AN/AN/A
       
Misc. federal credits$4.7 million$12.3 million$1.8 million$15.3 million$3.1 million$1.5 million
Year(s) of expiration2038-20412035-20412038-20412037-20412036-20412036-2041
       
State credits$— million$— million$1.3 million$—million$2.9 million$9 million
Year(s) of expirationN/AN/A2022-2025N/A20272022-2025

As a result of the accounting for uncertain tax positions, the amount of the deferred tax assets reflected in the financial statements is less than the amount of the tax effect of the federal and state net operating loss carryovers and tax credit carryovers.

Unrecognized tax benefits

Accounting standards establish a “more-likely-than-not” recognition threshold that must be met before a tax benefit can be recognized in the financial statements.  If a tax deduction is taken on a tax return but does not meet the more-likely-than-not recognition threshold, an increase in income tax liability, above what is payable on the tax return, is required to be recorded.  A reconciliation of Entergy’s beginning and ending amount of unrecognized tax benefits is as follows:
 202120202019
 (In Thousands)
Gross balance at January 1$5,699,339 $7,383,154 $7,181,482 
Additions based on tax positions related to the current year101,623 669,207 731,276 
Additions for tax positions of prior years33,419 98,591 151,628 
Reductions for tax positions of prior years (74,413)(935,735)(681,232)
Settlements— (1,515,878)— 
Gross balance at December 315,759,968 5,699,339 7,383,154 
Offsets to gross unrecognized tax benefits:   
Loss and tax credit carryovers(4,987,799)(4,710,214)(5,831,587)
Cash paid to taxing authorities(60,000)(10,000)(10,000)
Unrecognized tax benefits net of unused tax attributes, refund claims and payments (a)$712,169 $979,125 $1,541,567 
(a)Potential tax liability above what is payable on tax returns

The balances of unrecognized tax benefits include $2,256 million, $2,208 million, and $2,421 million as of December 31, 2021, 2020, and 2019, respectively, which, if recognized, would lower the effective income tax rates.  Because of the effect of deferred tax accounting, the remaining balances of unrecognized tax benefits of $3,504 million, $3,491 million, and $4,962 million as of December 31, 2021, 2020, and 2019, respectively, if disallowed, would not affect the annual effective income tax rate but would accelerate the payment of cash to the taxing authority to an earlier period.

Entergy accrues interest expense, if any, related to unrecognized tax benefits in income tax expense.  Entergy’s December 31, 2021, 2020, and 2019 accrued balance for the possible payment of interest is approximately $52 million, $44 million, and $48 million, respectively. Interest (net-of-tax) of $8 million, ($4) million, and $4 million was recorded in 2021, 2020, and 2019, respectively.

A reconciliation of the Registrant Subsidiaries’ beginning and ending amount of unrecognized tax benefits for 2021, 2020, and 2019 is as follows:
2021Entergy ArkansasEntergy LouisianaEntergy MississippiEntergy New OrleansEntergy TexasSystem Energy
 (In Thousands)
Gross balance at January 1, 2021$1,364,635 $640,295 $549,717 $639,546 $521,932 $21,652 
Additions based on tax positions related to the current year30,419 13,437 684 1,050 32,616 1,753 
Additions for tax positions of prior years15,013 9,304 1,504 2,315 1,897 
Reductions for tax positions of prior years(1,573)(58,408)(2,336)(1,105)(4,568)(1,946)
Gross balance at December 31, 20211,408,494 604,628 549,569 639,497 552,295 23,356 
Offsets to gross unrecognized tax benefits:      
Loss and tax credit carryovers(992,643)(604,628)(388,728)(484,899)(540,694)(8,576)
Unrecognized tax benefits net of unused tax attributes and payments$415,851 $— $160,841 $154,598 $11,601 $14,780 

2020Entergy ArkansasEntergy LouisianaEntergy MississippiEntergy New OrleansEntergy TexasSystem Energy
 (In Thousands)
Gross balance at January 1, 2020$1,341,242 $2,381,653 $566,287 $716,773 $21,406 $473,331 
Additions based on tax positions related to the current year (a)9,403 35,681 5,619 2,430 504,362 4,013 
Additions for tax positions of prior years13,400 10,508 1,156 294 799 4,606 
Reductions for tax positions of prior years(11,346)(679,601)(24,173)(80,267)(5,559)(41,466)
Settlements11,936 (1,107,946)828 316 924 (418,832)
Gross balance at December 31, 20201,364,635 640,295 549,717 639,546 521,932 21,652 
Offsets to gross unrecognized tax benefits:      
Loss and tax credit carryovers(1,112,628)(640,295)(465,679)(451,922)(507,720)(7,413)
Unrecognized tax benefits net of unused tax attributes and payments$252,007 $— $84,038 $187,624 $14,212 $14,239 
2019Entergy ArkansasEntergy LouisianaEntergy MississippiEntergy New OrleansEntergy TexasSystem Energy
 (In Thousands)
Gross balance at January 1, 2019$1,298,662 $2,400,171 $508,765 $686,687 $17,802 $467,487 
Additions based on tax positions related to the current year84,335 28,705 68,594 40,676 2,312 5,496 
Additions for tax positions of prior years20,399 25,090 1,651 489 1,299 2,186 
Reductions for tax positions of prior years(62,154)(72,313)(12,723)(11,079)(7)(1,838)
Gross balance at December 31, 20191,341,242 2,381,653 566,287 716,773 21,406 473,331 
Offsets to gross unrecognized tax benefits:      
Loss and tax credit carryovers(1,134,187)(1,573,257)(506,976)(445,430)(3,944)(8,392)
Unrecognized tax benefits net of unused tax attributes and payments$207,055 $808,396 $59,311 $271,343 $17,462 $464,939 

(a)The primary additions for Entergy Texas in 2020 are related to the mark-to-market treatment discussed in “Other Tax Matters - Tax Accounting Methods” below.

The Registrant Subsidiaries’ balances of unrecognized tax benefits included amounts which, if recognized, would have reduced income tax expense as follows:
December 31,
 202120202019
 (In Millions)
Entergy Arkansas$262.1 $259.3 $203.3 
Entergy Louisiana$66.3 $63.8 $556.3 
Entergy Mississippi$51.7 $50.7 $1.9 
Entergy New Orleans$228.6 $203.5 $242.7 
Entergy Texas$2.6 $6.1 $5.7 
System Energy$1.7 $0.5 $— 

Accrued balances for the possible payment of interest related to unrecognized tax benefits are as follows:
December 31,
 202120202019
 (In Millions)
Entergy Arkansas$2.7 $2.3 $3.1 
Entergy Louisiana$3.7 $3.4 $14.2 
Entergy Mississippi$2.4 $1.9 $1.7 
Entergy New Orleans$5.2 $3.9 $4.7 
Entergy Texas$1.1 $0.9 $1.1 
System Energy$12.1 $11.9 $14.5 
The Registrant Subsidiaries record interest and penalties related to unrecognized tax benefits in income tax expense.  No penalties were recorded in 2021, 2020, and 2019. Interest (net-of-tax) was recorded as follows:
202120202019
(In Millions)
Entergy Arkansas$0.4 ($0.8)$1.4 
Entergy Louisiana$0.3 ($10.8)($3.7)
Entergy Mississippi$0.5 $0.2 $0.5 
Entergy New Orleans$1.3 ($0.8)$2.0 
Entergy Texas$0.2 ($0.2)$0.2 
System Energy$0.2 ($2.6)$1.3 

Income Tax Audits

Entergy and its subsidiaries file U.S. federal and various state income tax returns.  IRS examinations are complete for years before 2016. All state taxing authorities’ examinations are complete for years before 2014. Entergy regularly defends its positions and works with the IRS to resolve audits.  The resolution of audit issues could result in significant changes to the amounts of unrecognized tax benefits in the next twelve months.

2014-2015 IRS Audit

The IRS completed its examination of the 2014 and 2015 tax years and issued its 2014-2015 RAR in November 2020. Entergy agreed to all proposed adjustments contained in the RAR. Entergy and the Registrant Subsidiaries recorded the effects of the adjustments associated with the audit in 2020.

In October 2015 two of Entergy’s Louisiana utilities, Entergy Gulf States Louisiana and Entergy Louisiana, combined their businesses into a legal entity which is identified as Entergy Louisiana herein. The structure of the business combination required Entergy to recognize a gain for income tax purposes which resulted in an increase in the tax basis of the assets for Entergy Louisiana. This resulted in recognition in 2015 of a $334 million permanent difference and income tax benefit, net of the uncertain tax position recorded on the transaction.

Primarily related to resolution of the business combination issues, completion of the 2014-2015 IRS audit in 2020 resulted in a $230 million reduction to deferred income tax expense for Entergy. This reduction to deferred income tax expense includes: Entergy Louisiana reversing its provision for uncertain tax position with respect to the business combination, which resulted in a reduction to deferred income tax expense of $383 million; Entergy Corporation recording an increase to deferred tax expense of $61 million and Entergy Wholesale Commodities recording an increase to deferred tax expense of $105 million from the re-measurement of deferred tax assets associated with the resolved uncertain tax position; and miscellaneous other individually insignificant benefits totaling $13 million.

The completion of the 2014-2015 tax audit also resulted in a $31 million reduction to income tax expense associated with Entergy Louisiana’s method of accounting related to the adoption of tangible property regulations. As a result of the settlement of the tangible property regulation tax position, Entergy Louisiana was required to record a $33 million ($24 million net-of-tax) regulatory charge and a corresponding regulatory liability to reflect its obligation to customers pursuant to a prior regulatory settlement.

Finally, upon completion of the 2014-2015 tax audit, Entergy New Orleans recorded a reduction to income tax expense of $8 million associated with claims for mark-to-market deductions.

In the first quarter 2020, Entergy and the IRS agreed on the treatment of funds received by Entergy Louisiana in conjunction with the Act 55 financing of Hurricane Isaac storm costs, which resulted in a net reduction
of income tax expense of approximately $32 million. As a result of the settlement, the position was partially sustained, and Entergy Louisiana recorded a reduction of income tax expense of approximately $58 million primarily due to the reversal of a provision for uncertain tax positions in excess of the agreed-upon settlement. As a result of the IRS settlement, Entergy Louisiana recorded a $29 million ($21 million net-of-tax) regulatory charge and a corresponding regulatory liability to reflect its obligation to customers pursuant to the LPSC Hurricane Isaac Act 55 financing order.

Additional effects of the completion of the 2014-2015 IRS tax audit are discussed below within Tax Accounting Methods.

Other Tax Matters

Tax Cuts and Jobs Act (TCJA)

The most significant effect of the TCJA for Entergy and the Registrant Subsidiaries was the change in the federal corporate income tax rate from 35% to 21%, effective January 1, 2018.

TCJA also limited the deduction for net business interest expense to 30 percent of adjusted taxable income, which is similar to earnings before interest, taxes, depreciation, and amortization. The limitation does not apply to interest expense that is properly allocable to a trade or business classified as a regulated public utility. This was further modified by a temporary provision of the CARES Act resulting in an increase of the adjusted taxable income limitation from 30% to 50% for tax years that begin in 2019 or 2020.

The IRS issued final regulations which are effective for Entergy beginning with the 2021 tax year. The regulations provide that if 90% of a tax group’s consolidated assets consist of regulated utility property, the entire consolidated tax group will be treated as a regulated public utility and all of the consolidated group’s interest expense will be currently tax deductible. Entergy expects that this provision will continue to apply to Entergy’s business operations making the application of this limitation to Entergy less likely. The provision has not resulted in Entergy having to report any significant business interest expense limitations on its tax returns.

With respect to the federal corporate income tax rate change from 35% to 21% in 2017, Entergy and the Registrant Subsidiaries recorded a regulatory liability associated with the decrease in the net accumulated deferred income tax liability, which is often referred to as “excess ADIT,” a significant portion of which has been paid to customers in 2019, 2020 and 2021 in the form of lower rates. Entergy’s December 31, 2021 and December 31, 2020 balance sheets reflect a regulatory liability of $1.3 billion and $1.6 billion, respectively, as a result of the re-measurement of deferred tax assets and liabilities from the income tax rate change, amortization of excess ADIT, and payments to customers during 2019, 2020 and 2021. Entergy’s regulatory liability for income taxes includes a gross-up at the applicable tax rate because of the effect that excess ADIT has on the ratemaking formula. The regulatory liability for income taxes includes the effect of a) the reduction of the net deferred tax liability resulting in excess ADIT, and b) the tax gross-up of excess ADIT. The Registrant Subsidiaries’ December 31, 2021 and December 31, 2020 balance sheets reflect net regulatory liabilities for income taxes as follows:
20212020
(In Millions)
Entergy Arkansas$432 $467 
Entergy Louisiana$338 $479 
Entergy Mississippi$212 $224 
Entergy New Orleans$42 $59 
Entergy Texas$171 $205 
System Energy$113 $152 
Excess ADIT is generally classified into two categories: 1) the portion that is subject to the normalization requirements of the TCJA, i.e., “protected”, and 2) the portion that is not subject to such normalization provisions, referred to as “unprotected”. The TCJA provides that the normalization method of accounting for income taxes is required for excess ADIT associated with public utility property. The TCJA provides for the use of the average rate assumption method (ARAM) for the determination of the timing of the return of excess ADIT associated with such property. Under ARAM, the excess ADIT is reduced over the remaining life of the asset. Remaining asset lives vary for each Registrant Subsidiary, but the average life of public utility property is typically 30 years or longer. Entergy will amortize the protected portion of the excess ADIT in conformity with the normalization requirements. The Registrant Subsidiaries’ net regulatory liability for income taxes as of December 31, 2021 and December 31, 2020, includes protected excess ADIT as follows:
20212020
(In Millions)
Entergy Arkansas$463 $490 
Entergy Louisiana$669 $721 
Entergy Mississippi$237 $248 
Entergy New Orleans$56 $61 
Entergy Texas$208 $215 
System Energy$148 $173 

Payment of the unprotected excess accumulated deferred income taxes results in a reduction in the regulatory liability for income taxes and a corresponding reduction in income tax expense. This has a significant effect on the effective tax rate for the period as compared to the statutory tax rate. The Registrant Subsidiaries’ net regulatory liability for income taxes as of December 31, 2021 and December 31, 2020, includes unprotected excess ADIT as follows:
20212020
(In Millions)
Entergy Arkansas$12 $11 
Entergy Louisiana$148 $223 
Entergy New Orleans$— $3 
Entergy Texas$26 $54 
System Energy$— $16 

The return of unprotected excess accumulated deferred income taxes reduced Entergy’s and the Registrant Subsidiaries’ regulatory liability for income taxes as follows for 2021 and 2020:
20212020
(In Millions)
Entergy$88 $74 
Entergy Arkansas$8 $8 
Entergy Louisiana$33 $31 
Entergy New Orleans$1 $6 
Entergy Texas$28 $29 
System Energy$18 $— 

In addition to the protected and unprotected excess ADIT amounts, the net regulatory liability for income taxes includes other regulatory assets and liabilities for income taxes associated with AFUDC, which is described in Note 1 to the financial statements.
Included in the effect of the computation of the changes in deferred tax assets and liabilities is the recognition threshold and measurement of uncertain tax positions resulting in unrecognized tax benefits. The final economic outcome of such unrecognized tax benefits is generally the result of a negotiated settlement with the IRS that often differs from the amount that is recorded as realizable under GAAP. The intrinsic uncertainty with respect to all such tax positions means that the difference between current estimates of such amounts likely to be realized and actual amounts realized upon settlement may have an effect on income tax expense and the regulatory liability for income taxes in future periods.

Entergy anticipates that the effect of TCJA may continue to have ramifications that require adjustments in the future as certain events occur. These events include: 1) IRS audit adjustments to or amendments of federal and state income tax returns that include modifications to the computation of taxable income resulting from TCJA; and 2) additional guidance, interpretations, or rulings by the U.S. Department of the Treasury or the IRS. The potential exists for these types of events to result in future tax expense adjustments because of the difference in the federal corporate income tax rate between past and future periods and the effect of the tax rate change on ratemaking. In turn, these events also could potentially affect the regulatory liability for income taxes.

Coronavirus Aid, Relief, and Economic Security Act

In response to the economic impacts of the COVID-19 pandemic, President Trump signed the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) into law on March 27, 2020. The CARES Act provisions that result in the most significant opportunities for tax relief to Entergy and the Registrant Subsidiaries are (i) permitting a five-year carryback of 2018-2020 NOLs, (ii) removing the 80 percent limitation on NOLs carried to tax years beginning before 2021, (iii) increasing the limitation on interest expense deductibility for 2019 and 2020, (iv) accelerating available refunds for minimum tax credit carryforwards, modifying limitations on charitable contributions during 2020, and (v) delaying the payment of employer payroll taxes. Entergy deferred approximately $64 million of 2020 payroll tax payments, payable in equal installments over two years. The initial installment of $32 million was paid in December 2021. The second installment will be paid in December 2022.

Entergy Wholesale Commodities Restructuring

In the fourth quarter 2019, two separate events occurred resulting in a reduction of tax expense of $174 million. In November 2019 an Entergy Wholesale Commodities subsidiary recognized a reduction in income tax expense of $18 million in connection with the accounting method on power contracts associated with the Palisades nuclear power station. Additionally, Entergy’s ownership of Indian Point 2 and Indian Point 3 was restructured. The restructuring required Entergy to recognize Indian Point 2 and Indian Point 3 nuclear decommissioning liabilities for income tax purposes resulting in a tax accounting permanent difference that reduced income tax expense, net of unrecognized tax benefits, by $156 million. The accrual of the nuclear decommissioning liabilities also required Entergy to recognize a gain for income tax purposes, a portion of which resulted in an increase in the tax basis of the assets. Recognition of the gain and the increase in the tax basis of the assets represents a tax accounting temporary difference.

Immediately prior to the restructuring, through its ownership of Indian Point 2 and Indian Point 3, Entergy donated property to Stony Brook University and recognized an associated tax deduction resulting in a decrease to tax expense of $19 million.

In the fourth quarter 2020, Entergy’s ownership of Palisades was restructured. The restructuring required Entergy to recognize Palisades’ nuclear decommissioning liability for income tax purposes resulting in a tax accounting permanent difference that reduced income tax expense, net of unrecognized tax benefits, by $9.2 million. The accrual of the nuclear decommissioning liability also required Entergy to recognize a gain for income tax purposes, a portion of which resulted in an increase in the tax basis of the assets. Recognition of the gain and the increase in the tax basis of the assets represents a tax accounting temporary difference.
Tax Accounting Methods

In the fourth quarter 2015, System Energy and Entergy Louisiana adopted a new method of accounting for income tax return purposes in which their nuclear decommissioning costs will be treated as production costs of electricity includable in cost of goods sold. The new method resulted in a reduction of taxable income of $1.2 billion for System Energy and $2.2 billion for Energy Louisiana.

In conjunction with the 2014-2015 IRS audit discussed above, the IRS issued proposed adjustments concerning the nuclear decommissioning tax position allowing System Energy to include $102 million of its decommissioning liability in cost of goods sold, and Entergy Louisiana to include $221 million of its decommissioning liability in cost of goods sold. Entergy, System Energy, and Entergy Louisiana agreed to the proposed adjustments included in the RAR.

As a result of System Energy being allowed to include part of its decommissioning liability in cost of goods sold, System Energy and Entergy recorded a deferred tax liability of $26 million. System Energy also recorded federal and state taxes payable of $402 million. However, on a consolidated basis, Entergy utilized tax loss carryovers to offset the federal taxable income adjustment and did not record federal taxes payable as a result of the outcome of this uncertain tax position.

As a result of Entergy Louisiana being allowed to include part of its decommissioning liability in cost of goods sold, Entergy Louisiana and Entergy recorded a deferred tax liability of $60 million. Both Entergy Louisiana and Entergy utilized tax loss carryovers to offset the taxable income adjustment and accordingly did not record taxes payable as a result of the outcome of this uncertain tax position.

The partial disallowance of this uncertain tax position to include the decommissioning liability in cost of goods sold resulted in a $1.5 billion decrease in the balance of unrecognized tax benefits related to federal and state taxes for Entergy. Additionally, both System Energy and Entergy Louisiana recorded a reduction to their balances of unrecognized tax benefits for federal and state taxes of $461 million and $1.1 billion, respectively.

Entergy Arkansas adopted the same method of accounting for its nuclear decommissioning costs which resulted in a $1.8 billion reduction in taxable income on its 2018 tax return.

In 2016, Entergy Louisiana elected mark-to-market income tax treatment for various wholesale electric power purchase and sale agreements, including Entergy Louisiana’s contract to purchase electricity from the Vidalia hydroelectric facility and from System Energy under the Unit Power Sales Agreement. The election resulted in a $2.2 billion deductible temporary difference. In 2017, Entergy New Orleans also elected mark-to-market income tax treatment for wholesale electric contracts which resulted in a $1.1 billion deductible temporary difference. In 2018, Entergy Arkansas and Entergy Mississippi accrued deductible temporary differences related to mark-to-market tax accounting for wholesale electric contracts of $2.1 billion and $1.9 billion, respectively. Additionally, in 2020, Entergy Texas elected mark-to-market income tax treatment for wholesale electric power purchase and sale agreements which resulted in a $2.5 billion deductible temporary difference.

Arkansas and Louisiana Corporate Income Tax Rate Changes

In April 2019 and December 2021 the State of Arkansas enacted corporate income tax law changes that phased in rate reductions from the former rate of 6.5% to 6.2% in 2021, 5.9% in 2022, and 5.7% in 2023.    As a result of the 2019 rate reduction, Entergy Arkansas computed a regulatory liability for income taxes as of December 31, 2020 of approximately $21 million, which includes a tax gross-up related to the treatment of income taxes in the retail and wholesale ratemaking formulas and has been included in the appropriate rate mechanisms. Entergy Arkansas recorded an incremental regulatory liability of $11 million associated with the rate reduction enacted in December 2021. The Arkansas tax law enactment also phases in an increase to the net operating loss carryover period from five to ten years.
Pursuant to legislation enacted in 2021 and approved by Louisiana citizens by amendment to the state constitution, beginning January 1, 2022, federal income taxes paid will no longer be deductible for state income tax purposes, and the top Louisiana corporate income tax rate will be reduced from 8% to 7.5%. As a result of this change in Louisiana tax law, the Louisiana applicable tax rate increased by 0.85%. Accordingly, deferred tax assets and liabilities were adjusted to reflect the new applicable federal and state rates. Legislation enacted in 2021 also provides that Louisiana net operating losses generally have an indefinite carryover period.

Entergy recorded a net increase to its deferred tax asset of $27 million. Entergy Louisiana and Entergy New Orleans recorded net increases to their deferred tax liabilities before consideration of the tax gross-up of $77 million and $8 million, respectively, which were offset by regulatory assets for income taxes. Therefore, these increases had no effect on tax expense. However, the increase of deferred tax assets associated with certain assets reduced tax expense for Entergy Louisiana and Entergy New Orleans by $6 million and $2 million, respectively.

Consolidated Income Tax Return of Entergy Corporation

In September 2019, Entergy Utility Holding Company, LLC and its regulated, wholly-owned subsidiaries including Entergy Arkansas, Entergy Louisiana, Entergy Mississippi, and Entergy New Orleans, became eligible to and joined the Entergy Corporation consolidated federal income tax group.  As a result of these four Utility operating companies re-joining the Entergy Corporation consolidated tax return group, Entergy was able to recognize a $41 million deferred tax asset associated with a previously unrecognized net operating loss carryover.

In September 2019, Entergy Texas issued $35 million of 5.375% Series A preferred stock with a liquidation value of $25 per share resulting in the disaffiliation and de-consolidation of Entergy Texas from the consolidated federal income tax return of Entergy Corporation.  These changes will not affect the accrual or allocation of income taxes for the Registrant Subsidiaries. See Note 6 to the financial statements for discussion of the preferred stock issuance.

Vermont Yankee

The Vermont Yankee transaction resulted in Entergy generating a net deferred tax asset in January 2019.  The deferred tax asset could not be fully realized by Entergy in the first quarter 2019; accordingly, Entergy accrued a net tax expense of $29 million on the disposition of Vermont Yankee. See Note 14 to the financial statements for discussion of the Vermont Yankee transaction.

Stock Compensation

In accordance with stock compensation accounting rules, Entergy and the Registrant Subsidiaries recognized excess tax deductions as a reduction of income tax expense in the first quarter 2020. Due to the vesting and exercise of certain Entergy stock-based awards, Entergy recorded a permanent tax reduction of approximately $24.7 million, including $4.8 million for Entergy Arkansas, $8.6 million for Entergy Louisiana, $2.7 million for Entergy Mississippi, $1.5 million for Entergy New Orleans, $2.7 million for Entergy Texas, and $1.3 million for System Energy.
System Energy [Member]  
Income Taxes INCOME TAXES (Entergy Corporation, Entergy Arkansas, Entergy Louisiana, Entergy Mississippi, Entergy New Orleans, Entergy Texas, and System Energy)
Income taxes for 2021, 2020, and 2019 for Entergy Corporation and Subsidiaries consist of the following:
 202120202019
 (In Thousands)
Current:   
Federal($5,003)$5,807 ($14,416)
State(8,995)57,939 6,535 
Total(13,998)63,746 (7,881)
Deferred and non-current - net205,891 (190,635)(155,956)
Investment tax credit adjustments - net(519)5,383 (5,988)
Income taxes$191,374 ($121,506)($169,825)

Income taxes for 2021, 2020, and 2019 for Entergy’s Registrant Subsidiaries consist of the following:
2021Entergy ArkansasEntergy LouisianaEntergy MississippiEntergy New OrleansEntergy TexasSystem Energy
(In Thousands)
Current:      
Federal($20,285)($24,053)($5,868)($6,724)($189)$29,416 
State529 2,459 (11,506)(413)1,261 (10,258)
Total(19,756)(21,594)(17,374)(7,137)1,072 19,158 
Deferred and non-current - net96,180 146,786 60,861 12,870 25,087 (25,229)
Investment tax credit adjustments - net(1,229)(4,783)1,836 203 (633)4,094 
Income taxes$75,195 $120,409 $45,323 $5,936 $25,526 ($1,977)

2020Entergy ArkansasEntergy LouisianaEntergy MississippiEntergy New OrleansEntergy TexasSystem Energy
 (In Thousands)
Current:      
Federal($44,627)$62,728 ($14,580)$293 ($5,603)$372,206 
State(2,563)4,457 (1,316)(303)2,658 55,551 
Total(47,190)67,185 (15,896)(10)(2,945)427,757 
Deferred and non-current - net96,195 (444,647)43,640 (18,153)6,619 (405,928)
Investment tax credit adjustments - net(1,228)(4,862)(554)13,956 (632)(1,286)
Income taxes$47,777 ($382,324)$27,190 ($4,207)$3,042 $20,543 
2019Entergy ArkansasEntergy LouisianaEntergy MississippiEntergy New OrleansEntergy TexasSystem Energy
 (In Thousands)
Current:      
Federal($14,549)($20,173)($8,939)($5,822)$16,035 $16,256 
State(714)(735)5,823 1,856 663 (2,831)
Total(15,263)(20,908)(3,116)(3,966)16,698 13,425 
Deferred and non-current - net(30,278)147,453 34,579 4,248 (69,963)422 
Investment tax credit adjustments - net(1,228)(4,922)(597)(96)(631)1,502 
Income taxes($46,769)$121,623 $30,866 $186 ($53,896)$15,349 

Total income taxes for Entergy Corporation and Subsidiaries differ from the amounts computed by applying the statutory income tax rate to income before income taxes.  The reasons for the differences for the years 2021, 2020, and 2019 are:
 202120202019
 (In Thousands)
Net income attributable to Entergy Corporation$1,118,492 $1,388,334 $1,241,226 
Preferred dividend requirements of subsidiaries227 18,319 17,018 
Consolidated net income1,118,719 1,406,653 1,258,244 
Income taxes191,374 (121,506)(169,825)
Income before income taxes$1,310,093 $1,285,147 $1,088,419 
Computed at statutory rate (21%)$275,120 $269,881 $228,568 
Increases (reductions) in tax resulting from:   
State income taxes net of federal income tax effect79,273 60,087 61,791 
Regulatory differences - utility plant items(57,556)(53,229)(45,336)
Equity component of AFUDC(14,799)(25,080)(30,444)
Amortization of investment tax credits(7,695)(8,386)(8,093)
Flow-through / permanent differences(5,585)11,099 (2,059)
Amortization of excess ADIT (a)(66,478)(59,629)(205,614)
Arkansas and Louisiana Rate Changes (b)(27,108)— — 
IRS audit adjustment (d)— (301,041)— 
Entergy Wholesale Commodities restructuring (c)— (9,223)(173,725)
Stock compensation (e)— (25,591)— 
Charitable contribution (c)— — (19,101)
Net operating loss recognition— — (41,427)
Provision for uncertain tax positions16,533 15,208 7,332 
Valuation allowance(2,600)— 59,345 
Other - net2,269 4,398 (1,062)
Total income taxes as reported$191,374 ($121,506)($169,825)
Effective Income Tax Rate14.6 %(9.5 %)(15.6 %)

(a)See “Other Tax Matters - Tax Cuts and Jobs Act” below for discussion of the amortization of excess accumulated deferred income taxes (ADIT) in 2019, 2020, and 2021 and the tax legislation enactment in 2017.
(b)See “Arkansas and Louisiana Corporate Income Tax Rate Changes” below for details.
(c)See Other Tax Matters - Entergy Wholesale Commodities Restructuring” below for discussion of the Entergy Wholesale Commodities restructuring in 2019, the ownership of Palisades restructuring in 2020, and the charitable contribution in 2019.
(d)See “Income Tax Audits - 2014-2015 IRS Audit” below for discussion of the resolution of the audit in 2020.
(e)See “Other Tax Matters - Stock Compensation” below for discussion of excess tax deductions.

Total income taxes for the Registrant Subsidiaries differ from the amounts computed by applying the statutory income tax rate to income before taxes.  The reasons for the differences for the years 2021, 2020, and 2019 are:
2021Entergy ArkansasEntergy LouisianaEntergy MississippiEntergy New OrleansEntergy TexasSystem Energy
 (In Thousands)
Net income$298,484 $653,984 $166,834 $31,798 $228,824 $106,814 
Income taxes75,195 120,409 45,323 5,936 25,526 (1,977)
Pretax income$373,679 $774,393 $212,157 $37,734 $254,350 $104,837 
Computed at statutory rate (21%)$78,473 $162,623 $44,553 $7,924 $53,413 $22,016 
Increases (reductions) in tax resulting from:     
State income taxes net of federal income tax effect19,633 41,030 9,305 2,579 1,553 5,385 
Regulatory differences - utility plant items(16,078)(14,123)(8,133)(4,332)(2,115)(12,776)
Equity component of AFUDC(3,207)(6,016)(1,701)(498)(2,077)(1,300)
Amortization of investment tax credits(1,201)(4,729)64 (56)(617)(1,155)
Flow-through / permanent differences(814)(2,655)124 1,559 (475)(1,235)
Amortization of excess ADIT (a)(5,845)(24,323)— (1,028)(21,929)(13,354)
Arkansas and Louisiana Rate Changes (b)398 (6,126)395 (1,569)216 115 
Non-taxable dividend income— (26,801)— — — — 
Provision for uncertain tax positions353 300 465 1,200 (2,716)200 
Valuation Allowance2,766 — — — — — 
Other - net717 1,229 251 157 273 127 
Total income taxes as reported$75,195 $120,409 $45,323 $5,936 $25,526 ($1,977)
Effective Income Tax Rate20.1 %15.5 %21.4 %15.7 %10.0 %(1.9 %)
2020Entergy ArkansasEntergy LouisianaEntergy MississippiEntergy New OrleansEntergy TexasSystem Energy
 (In Thousands)
Net income$245,232 $1,082,352 $140,583 $49,338 $215,073 $99,131 
Income taxes47,777 (382,324)27,190 (4,207)3,042 20,543 
Pretax income$293,009 $700,028 $167,773 $45,131 $218,115 $119,674 
Computed at statutory rate (21%)$61,532 $147,006 $35,232 $9,478 $45,804 $25,132 
Increases (reductions) in tax resulting from:
State income taxes net of federal income tax effect16,256 38,182 6,917 2,606 1,460 5,524 
Regulatory differences - utility plant items(8,034)(23,819)(7,441)(3,442)(7,673)(2,821)
Equity component of AFUDC(3,154)(8,012)(1,412)(1,331)(9,255)(1,916)
Amortization of investment tax credits(1,201)(4,811)(540)(61)(617)(1,155)
Flow-through / permanent differences(2,219)1,404 (102)498 766 (421)
Amortization of excess ADIT (a)(6,011)(26,293)18 (4,564)(22,780)— 
Stock compensation (d)(4,952)(9,004)(2,763)(1,526)(2,842)(1,300)
IRS audit adjustment (c)(6,351)(471,702)(3,768)(6,819)(2,091)(2,925)
Non-taxable dividend income— (26,795)— — — — 
Provision for uncertain tax positions1,200 300 800 800 — 300 
Other - net711 1,220 249 154 270 125 
Total income taxes as reported$47,777 ($382,324)$27,190 ($4,207)$3,042 $20,543 
Effective Income Tax Rate16.3 %(54.6 %)16.2 %(9.3 %)1.4 %17.2 %

2019Entergy ArkansasEntergy LouisianaEntergy MississippiEntergy New OrleansEntergy TexasSystem Energy
 (In Thousands)
Net income$262,964 $691,537 $119,925 $52,629 $159,397 $99,120 
Income taxes(46,769)121,623 30,866 186 (53,896)15,349 
Pretax income$216,195 $813,160 $150,791 $52,815 $105,501 $114,469 
Computed at statutory rate (21%)$45,401 $170,764 $31,666 $11,091 $22,155 $24,039 
Increases (reductions) in tax resulting from:      
State income taxes net of federal income tax effect15,954 42,854 5,563 3,443 360 5,134 
Regulatory differences - utility plant items(10,627)(19,421)(5,556)(1,532)(1,987)(6,213)
Equity component of AFUDC(3,255)(15,545)(1,755)(2,088)(5,973)(1,829)
Amortization of investment tax credits(1,201)(4,871)(160)(88)(617)(1,155)
Flow-through / permanent differences696 439 160 (741)560 (500)
Amortization of excess ADIT (a)(90,921)(28,531)203 (11,724)(69,091)(5,550)
Non-taxable dividend income— (26,795)— — — — 
Provision for uncertain tax positions(3,517)1,519 500 1,672 430 1,300 
Other - net701 1,210 245 153 267 123 
Total income taxes as reported($46,769)$121,623 $30,866 $186 ($53,896)$15,349 
Effective Income Tax Rate(21.6 %)15.0 %20.5 %0.4 %(51.1 %)13.4 %
(a)See “Other Tax Matters - Tax Cuts and Jobs Act” below for discussion of the amortization of excess accumulated deferred income taxes (ADIT) in 2019, 2020 and 2021 and the tax legislation enactment in 2017.
(b)See “Arkansas and Louisiana Corporate Income Tax Rate Changes” below for details.
(c)See “Income Tax Audits - 2014-2015 IRS Audit” below for discussion of the resolution of the audit in 2020.
(d)See “Other Tax Matters - Stock Compensation” below for discussion of excess tax deductions.


Significant components of accumulated deferred income taxes and taxes accrued for Entergy Corporation and Subsidiaries as of December 31, 2021 and 2020 are as follows:
 
 20212020
 (In Thousands)
Deferred tax liabilities:  
Plant basis differences - net($6,136,563)($4,795,422)
Regulatory assets(930,244)(429,996)
Nuclear decommissioning trusts/receivables(656,185)(1,188,235)
Pension, net regulatory asset(322,788)(327,445)
Combined unitary state taxes(7,255)(7,723)
Unbilled/deferred revenues— (9,152)
Accumulated storm damage provision(207,243)— 
Deferred fuel(85,310)(7,667)
Other(341,450)(549,355)
Total(8,687,038)(7,314,995)
Deferred tax assets:  
Nuclear decommissioning liabilities278,136 968,464 
Regulatory liabilities1,318,381 791,927 
Pension and other post-employment benefits208,128 278,486 
Sale and leaseback102,474 102,477 
Compensation79,798 89,279 
Accumulated deferred investment tax credit57,986 57,379 
Provision for allowances and contingencies82,286 71,598 
Power purchase agreements55,259 352,019 
Unbilled/deferred revenues26,683 — 
Net operating loss carryforwards2,868,424 1,580,109 
Capital losses and miscellaneous tax credits11,111 21,291 
Valuation allowance(325,239)(328,581)
Other200,032 230,291 
Total4,963,459 4,214,739 
Non-current accrued taxes (including unrecognized tax benefits)(929,032)(1,185,227)
Accumulated deferred income taxes and taxes accrued($4,652,611)($4,285,483)
Entergy’s estimated tax attributes carryovers and their expiration dates as of December 31, 2021 are as follows:
Carryover DescriptionCarryover AmountYear(s) of expiration
   
Federal net operating losses before 1/1/2018$6.2 billion2023-2027
Federal net operating losses - 1/1/2018 forward$21.1 billionN/A
State net operating losses$7.4 billion2022-2041
State net operating losses with no expiration$16.7 billionN/A
Federal and state charitable contributions$460.8 million2022-2026
Miscellaneous federal and state credits$73.1 million2022-2041

As a result of the accounting for uncertain tax positions, the amount of the deferred tax assets reflected in the financial statements is less than the amount of the tax effect of the federal and state net operating loss carryovers, tax credit carryovers, and other tax attributes reflected on income tax returns. Entergy evaluates the available positive and negative evidence to estimate whether sufficient future taxable income of the appropriate character will be generated to realize the benefits of existing deferred tax assets. When the evaluation indicates that Entergy will not be able to realize the existing benefits, a valuation allowance is recorded to reduce deferred tax assets to the realizable amount.

Because it is more likely than not that the benefits from certain state net operating losses and other deferred tax assets will not be utilized, valuation allowances totaling $325 million as of December 31, 2021 and $329 million as of December 31, 2020 have been provided on the deferred tax assets related to federal and state jurisdictions in which Entergy does not currently expect to be able to utilize certain separate company tax return attributes, preventing realization of such deferred tax assets. As a result of incurring costs related to Hurricane Ida restoration, certain Utility operating companies are entitled to an accelerated tax deduction which generated a taxable loss in various taxing jurisdictions. This accelerated deduction has impaired the realizability of a limited term carryover tax attribute. Accordingly, the impairment contributed to the activity reflected for the valuation allowance disclosed above.
Significant components of accumulated deferred income taxes and taxes accrued for the Registrant Subsidiaries as of December 31, 2021 and 2020 are as follows:
2021Entergy ArkansasEntergy LouisianaEntergy MississippiEntergy New OrleansEntergy TexasSystem Energy
 (In Thousands)
Deferred tax liabilities:      
Plant basis differences - net($1,158,523)($3,429,473)($681,968)($192,660)($654,252)($433,874)
Regulatory assets(226,687)(530,274)(34,799)(30,694)(45,470)(61,205)
Nuclear decommissioning trusts/receivables(175,882)(186,382)— — — (153,610)
Pension, net regulatory asset(92,881)(93,681)(22,253)(11,429)(19,914)(18,033)
Deferred fuel(27,497)(13,686)(30,409)(1,600)(10,139)(49)
Accumulated storm damage provision— (193,967)— — (13,276)— 
Other(77,820)(138,299)(29,108)(33,071)(2,526)(5,622)
Total(1,759,290)(4,585,762)(798,537)(269,454)(745,577)(672,393)
Deferred tax assets:      
Regulatory liabilities310,256 634,184 59,418 36,057 55,022 224,036 
Nuclear decommissioning liabilities123,568 (909)(433)94 9,432 
Pension and other post-employment benefits(26,577)73,006 (7,793)(16,090)(18,793)(1,925)
Sale and leaseback— — — — — 102,474 
Accumulated deferred investment tax credit7,518 30,666 2,723 4,391 1,958 10,729 
Provision for allowances and contingencies24,829 21,768 10,236 5,559 7,730 — 
Power purchase agreements— — 1,140 — (1,202)— 
Unbilled/deferred revenues3,331 9,919 2,306 971 10,196 — 
Compensation3,347 5,288 2,181 1,036 1,618 447 
Net operating loss carryforwards275,054 1,228,547 166,008 105,549 81 — 
Capital losses and miscellaneous tax credits— 5,141 1,258 10,977 883 1,958 
Other19,397 5,968 2,891 7,788 863 
Total740,723 2,013,578 240,369 155,805 58,450 347,153 
Non-current accrued taxes (including unrecognized tax benefits)(397,634)138,330 (161,929)(251,735)(5,369)(57,691)
Accumulated deferred income taxes and taxes accrued($1,416,201)($2,433,854)($720,097)($365,384)($692,496)($382,931)
2020Entergy ArkansasEntergy LouisianaEntergy MississippiEntergy New OrleansEntergy TexasSystem Energy
 (In Thousands)
Deferred tax liabilities:      
Plant basis differences - net($1,117,948)($2,481,976)($623,796)($83,457)($620,669)($407,125)
Regulatory assets(188,284)(95,135)(22,381)(20,276)(47,684)(56,496)
Nuclear decommissioning trusts/receivables(156,123)(148,040)— — — (131,985)
Pension, net funding(93,486)(95,854)(24,922)(11,564)(19,481)(20,330)
Deferred fuel— (4,210)(1,706)(1,393)— (314)
Other(54,753)(76,735)(27,565)(26,334)(141)(12,521)
Total(1,610,594)(2,901,950)(700,370)(143,024)(687,975)(628,771)
Deferred tax assets:      
Regulatory liabilities273,774 218,278 56,022 31,248 47,991 163,534 
Nuclear decommissioning liabilities123,319 7,767 — (419)121 29,916 
Pension and other post-employment benefits(24,747)72,724 (6,763)(13,997)(17,132)(1,344)
Sale and leaseback— — — — — 102,477 
Accumulated deferred investment tax credit7,971 31,155 2,261 4,197 2,088 9,706 
Provision for allowances and contingencies22,179 7,071 16,799 24,529 (4,094)— 
Power purchase agreements9,662 3,381 1,140 (5,324)(30,932)— 
Unbilled/deferred revenues4,242 (23,382)2,989 877 5,909 — 
Compensation2,264 3,240 1,670 761 1,308 48 
Net operating loss carryforwards119,555 363,806 54,262 26,564 53,052 — 
Capital losses and miscellaneous tax credits— 9,309 — 12,317 — 7,014 
Other16,036 6,958 3,507 8,128 2,232 
Total554,255 700,307 131,887 88,881 60,543 311,353 
Non-current accrued taxes (including unrecognized tax benefits)(229,784)63,121 (78,191)(284,571)(11,990)(42,417)
Accumulated deferred income taxes and taxes accrued($1,286,123)($2,138,522)($646,674)($338,714)($639,422)($359,835)
The Registrant Subsidiaries’ estimated tax attributes carryovers and their expiration dates as of December 31, 2021 are as follows:

 Entergy ArkansasEntergy LouisianaEntergy MississippiEntergy New OrleansEntergy TexasSystem Energy
       
Federal net operating losses before 1/1/2018$— billion$1.7 billion$— billion$0.9 billion$— billion$— billion
Year(s) of expirationN/A2035-2037N/A2037N/AN/A
Federal net operating losses - 1/1/2018 forward$4.5 billion$4.5 billion$2.1 billion$0.7 billion$2.6 billion$— billion
Year(s) of expirationN/AN/AN/AN/AN/AN/A
       
State net operating losses$4.8 billion$7.2 billion$2.3 billion$1.7 billion$— million$— million
Year(s) of expiration2023-2026N/A2038-2041N/AN/AN/A
       
Misc. federal credits$4.7 million$12.3 million$1.8 million$15.3 million$3.1 million$1.5 million
Year(s) of expiration2038-20412035-20412038-20412037-20412036-20412036-2041
       
State credits$— million$— million$1.3 million$—million$2.9 million$9 million
Year(s) of expirationN/AN/A2022-2025N/A20272022-2025

As a result of the accounting for uncertain tax positions, the amount of the deferred tax assets reflected in the financial statements is less than the amount of the tax effect of the federal and state net operating loss carryovers and tax credit carryovers.

Unrecognized tax benefits

Accounting standards establish a “more-likely-than-not” recognition threshold that must be met before a tax benefit can be recognized in the financial statements.  If a tax deduction is taken on a tax return but does not meet the more-likely-than-not recognition threshold, an increase in income tax liability, above what is payable on the tax return, is required to be recorded.  A reconciliation of Entergy’s beginning and ending amount of unrecognized tax benefits is as follows:
 202120202019
 (In Thousands)
Gross balance at January 1$5,699,339 $7,383,154 $7,181,482 
Additions based on tax positions related to the current year101,623 669,207 731,276 
Additions for tax positions of prior years33,419 98,591 151,628 
Reductions for tax positions of prior years (74,413)(935,735)(681,232)
Settlements— (1,515,878)— 
Gross balance at December 315,759,968 5,699,339 7,383,154 
Offsets to gross unrecognized tax benefits:   
Loss and tax credit carryovers(4,987,799)(4,710,214)(5,831,587)
Cash paid to taxing authorities(60,000)(10,000)(10,000)
Unrecognized tax benefits net of unused tax attributes, refund claims and payments (a)$712,169 $979,125 $1,541,567 
(a)Potential tax liability above what is payable on tax returns

The balances of unrecognized tax benefits include $2,256 million, $2,208 million, and $2,421 million as of December 31, 2021, 2020, and 2019, respectively, which, if recognized, would lower the effective income tax rates.  Because of the effect of deferred tax accounting, the remaining balances of unrecognized tax benefits of $3,504 million, $3,491 million, and $4,962 million as of December 31, 2021, 2020, and 2019, respectively, if disallowed, would not affect the annual effective income tax rate but would accelerate the payment of cash to the taxing authority to an earlier period.

Entergy accrues interest expense, if any, related to unrecognized tax benefits in income tax expense.  Entergy’s December 31, 2021, 2020, and 2019 accrued balance for the possible payment of interest is approximately $52 million, $44 million, and $48 million, respectively. Interest (net-of-tax) of $8 million, ($4) million, and $4 million was recorded in 2021, 2020, and 2019, respectively.

A reconciliation of the Registrant Subsidiaries’ beginning and ending amount of unrecognized tax benefits for 2021, 2020, and 2019 is as follows:
2021Entergy ArkansasEntergy LouisianaEntergy MississippiEntergy New OrleansEntergy TexasSystem Energy
 (In Thousands)
Gross balance at January 1, 2021$1,364,635 $640,295 $549,717 $639,546 $521,932 $21,652 
Additions based on tax positions related to the current year30,419 13,437 684 1,050 32,616 1,753 
Additions for tax positions of prior years15,013 9,304 1,504 2,315 1,897 
Reductions for tax positions of prior years(1,573)(58,408)(2,336)(1,105)(4,568)(1,946)
Gross balance at December 31, 20211,408,494 604,628 549,569 639,497 552,295 23,356 
Offsets to gross unrecognized tax benefits:      
Loss and tax credit carryovers(992,643)(604,628)(388,728)(484,899)(540,694)(8,576)
Unrecognized tax benefits net of unused tax attributes and payments$415,851 $— $160,841 $154,598 $11,601 $14,780 

2020Entergy ArkansasEntergy LouisianaEntergy MississippiEntergy New OrleansEntergy TexasSystem Energy
 (In Thousands)
Gross balance at January 1, 2020$1,341,242 $2,381,653 $566,287 $716,773 $21,406 $473,331 
Additions based on tax positions related to the current year (a)9,403 35,681 5,619 2,430 504,362 4,013 
Additions for tax positions of prior years13,400 10,508 1,156 294 799 4,606 
Reductions for tax positions of prior years(11,346)(679,601)(24,173)(80,267)(5,559)(41,466)
Settlements11,936 (1,107,946)828 316 924 (418,832)
Gross balance at December 31, 20201,364,635 640,295 549,717 639,546 521,932 21,652 
Offsets to gross unrecognized tax benefits:      
Loss and tax credit carryovers(1,112,628)(640,295)(465,679)(451,922)(507,720)(7,413)
Unrecognized tax benefits net of unused tax attributes and payments$252,007 $— $84,038 $187,624 $14,212 $14,239 
2019Entergy ArkansasEntergy LouisianaEntergy MississippiEntergy New OrleansEntergy TexasSystem Energy
 (In Thousands)
Gross balance at January 1, 2019$1,298,662 $2,400,171 $508,765 $686,687 $17,802 $467,487 
Additions based on tax positions related to the current year84,335 28,705 68,594 40,676 2,312 5,496 
Additions for tax positions of prior years20,399 25,090 1,651 489 1,299 2,186 
Reductions for tax positions of prior years(62,154)(72,313)(12,723)(11,079)(7)(1,838)
Gross balance at December 31, 20191,341,242 2,381,653 566,287 716,773 21,406 473,331 
Offsets to gross unrecognized tax benefits:      
Loss and tax credit carryovers(1,134,187)(1,573,257)(506,976)(445,430)(3,944)(8,392)
Unrecognized tax benefits net of unused tax attributes and payments$207,055 $808,396 $59,311 $271,343 $17,462 $464,939 

(a)The primary additions for Entergy Texas in 2020 are related to the mark-to-market treatment discussed in “Other Tax Matters - Tax Accounting Methods” below.

The Registrant Subsidiaries’ balances of unrecognized tax benefits included amounts which, if recognized, would have reduced income tax expense as follows:
December 31,
 202120202019
 (In Millions)
Entergy Arkansas$262.1 $259.3 $203.3 
Entergy Louisiana$66.3 $63.8 $556.3 
Entergy Mississippi$51.7 $50.7 $1.9 
Entergy New Orleans$228.6 $203.5 $242.7 
Entergy Texas$2.6 $6.1 $5.7 
System Energy$1.7 $0.5 $— 

Accrued balances for the possible payment of interest related to unrecognized tax benefits are as follows:
December 31,
 202120202019
 (In Millions)
Entergy Arkansas$2.7 $2.3 $3.1 
Entergy Louisiana$3.7 $3.4 $14.2 
Entergy Mississippi$2.4 $1.9 $1.7 
Entergy New Orleans$5.2 $3.9 $4.7 
Entergy Texas$1.1 $0.9 $1.1 
System Energy$12.1 $11.9 $14.5 
The Registrant Subsidiaries record interest and penalties related to unrecognized tax benefits in income tax expense.  No penalties were recorded in 2021, 2020, and 2019. Interest (net-of-tax) was recorded as follows:
202120202019
(In Millions)
Entergy Arkansas$0.4 ($0.8)$1.4 
Entergy Louisiana$0.3 ($10.8)($3.7)
Entergy Mississippi$0.5 $0.2 $0.5 
Entergy New Orleans$1.3 ($0.8)$2.0 
Entergy Texas$0.2 ($0.2)$0.2 
System Energy$0.2 ($2.6)$1.3 

Income Tax Audits

Entergy and its subsidiaries file U.S. federal and various state income tax returns.  IRS examinations are complete for years before 2016. All state taxing authorities’ examinations are complete for years before 2014. Entergy regularly defends its positions and works with the IRS to resolve audits.  The resolution of audit issues could result in significant changes to the amounts of unrecognized tax benefits in the next twelve months.

2014-2015 IRS Audit

The IRS completed its examination of the 2014 and 2015 tax years and issued its 2014-2015 RAR in November 2020. Entergy agreed to all proposed adjustments contained in the RAR. Entergy and the Registrant Subsidiaries recorded the effects of the adjustments associated with the audit in 2020.

In October 2015 two of Entergy’s Louisiana utilities, Entergy Gulf States Louisiana and Entergy Louisiana, combined their businesses into a legal entity which is identified as Entergy Louisiana herein. The structure of the business combination required Entergy to recognize a gain for income tax purposes which resulted in an increase in the tax basis of the assets for Entergy Louisiana. This resulted in recognition in 2015 of a $334 million permanent difference and income tax benefit, net of the uncertain tax position recorded on the transaction.

Primarily related to resolution of the business combination issues, completion of the 2014-2015 IRS audit in 2020 resulted in a $230 million reduction to deferred income tax expense for Entergy. This reduction to deferred income tax expense includes: Entergy Louisiana reversing its provision for uncertain tax position with respect to the business combination, which resulted in a reduction to deferred income tax expense of $383 million; Entergy Corporation recording an increase to deferred tax expense of $61 million and Entergy Wholesale Commodities recording an increase to deferred tax expense of $105 million from the re-measurement of deferred tax assets associated with the resolved uncertain tax position; and miscellaneous other individually insignificant benefits totaling $13 million.

The completion of the 2014-2015 tax audit also resulted in a $31 million reduction to income tax expense associated with Entergy Louisiana’s method of accounting related to the adoption of tangible property regulations. As a result of the settlement of the tangible property regulation tax position, Entergy Louisiana was required to record a $33 million ($24 million net-of-tax) regulatory charge and a corresponding regulatory liability to reflect its obligation to customers pursuant to a prior regulatory settlement.

Finally, upon completion of the 2014-2015 tax audit, Entergy New Orleans recorded a reduction to income tax expense of $8 million associated with claims for mark-to-market deductions.

In the first quarter 2020, Entergy and the IRS agreed on the treatment of funds received by Entergy Louisiana in conjunction with the Act 55 financing of Hurricane Isaac storm costs, which resulted in a net reduction
of income tax expense of approximately $32 million. As a result of the settlement, the position was partially sustained, and Entergy Louisiana recorded a reduction of income tax expense of approximately $58 million primarily due to the reversal of a provision for uncertain tax positions in excess of the agreed-upon settlement. As a result of the IRS settlement, Entergy Louisiana recorded a $29 million ($21 million net-of-tax) regulatory charge and a corresponding regulatory liability to reflect its obligation to customers pursuant to the LPSC Hurricane Isaac Act 55 financing order.

Additional effects of the completion of the 2014-2015 IRS tax audit are discussed below within Tax Accounting Methods.

Other Tax Matters

Tax Cuts and Jobs Act (TCJA)

The most significant effect of the TCJA for Entergy and the Registrant Subsidiaries was the change in the federal corporate income tax rate from 35% to 21%, effective January 1, 2018.

TCJA also limited the deduction for net business interest expense to 30 percent of adjusted taxable income, which is similar to earnings before interest, taxes, depreciation, and amortization. The limitation does not apply to interest expense that is properly allocable to a trade or business classified as a regulated public utility. This was further modified by a temporary provision of the CARES Act resulting in an increase of the adjusted taxable income limitation from 30% to 50% for tax years that begin in 2019 or 2020.

The IRS issued final regulations which are effective for Entergy beginning with the 2021 tax year. The regulations provide that if 90% of a tax group’s consolidated assets consist of regulated utility property, the entire consolidated tax group will be treated as a regulated public utility and all of the consolidated group’s interest expense will be currently tax deductible. Entergy expects that this provision will continue to apply to Entergy’s business operations making the application of this limitation to Entergy less likely. The provision has not resulted in Entergy having to report any significant business interest expense limitations on its tax returns.

With respect to the federal corporate income tax rate change from 35% to 21% in 2017, Entergy and the Registrant Subsidiaries recorded a regulatory liability associated with the decrease in the net accumulated deferred income tax liability, which is often referred to as “excess ADIT,” a significant portion of which has been paid to customers in 2019, 2020 and 2021 in the form of lower rates. Entergy’s December 31, 2021 and December 31, 2020 balance sheets reflect a regulatory liability of $1.3 billion and $1.6 billion, respectively, as a result of the re-measurement of deferred tax assets and liabilities from the income tax rate change, amortization of excess ADIT, and payments to customers during 2019, 2020 and 2021. Entergy’s regulatory liability for income taxes includes a gross-up at the applicable tax rate because of the effect that excess ADIT has on the ratemaking formula. The regulatory liability for income taxes includes the effect of a) the reduction of the net deferred tax liability resulting in excess ADIT, and b) the tax gross-up of excess ADIT. The Registrant Subsidiaries’ December 31, 2021 and December 31, 2020 balance sheets reflect net regulatory liabilities for income taxes as follows:
20212020
(In Millions)
Entergy Arkansas$432 $467 
Entergy Louisiana$338 $479 
Entergy Mississippi$212 $224 
Entergy New Orleans$42 $59 
Entergy Texas$171 $205 
System Energy$113 $152 
Excess ADIT is generally classified into two categories: 1) the portion that is subject to the normalization requirements of the TCJA, i.e., “protected”, and 2) the portion that is not subject to such normalization provisions, referred to as “unprotected”. The TCJA provides that the normalization method of accounting for income taxes is required for excess ADIT associated with public utility property. The TCJA provides for the use of the average rate assumption method (ARAM) for the determination of the timing of the return of excess ADIT associated with such property. Under ARAM, the excess ADIT is reduced over the remaining life of the asset. Remaining asset lives vary for each Registrant Subsidiary, but the average life of public utility property is typically 30 years or longer. Entergy will amortize the protected portion of the excess ADIT in conformity with the normalization requirements. The Registrant Subsidiaries’ net regulatory liability for income taxes as of December 31, 2021 and December 31, 2020, includes protected excess ADIT as follows:
20212020
(In Millions)
Entergy Arkansas$463 $490 
Entergy Louisiana$669 $721 
Entergy Mississippi$237 $248 
Entergy New Orleans$56 $61 
Entergy Texas$208 $215 
System Energy$148 $173 

Payment of the unprotected excess accumulated deferred income taxes results in a reduction in the regulatory liability for income taxes and a corresponding reduction in income tax expense. This has a significant effect on the effective tax rate for the period as compared to the statutory tax rate. The Registrant Subsidiaries’ net regulatory liability for income taxes as of December 31, 2021 and December 31, 2020, includes unprotected excess ADIT as follows:
20212020
(In Millions)
Entergy Arkansas$12 $11 
Entergy Louisiana$148 $223 
Entergy New Orleans$— $3 
Entergy Texas$26 $54 
System Energy$— $16 

The return of unprotected excess accumulated deferred income taxes reduced Entergy’s and the Registrant Subsidiaries’ regulatory liability for income taxes as follows for 2021 and 2020:
20212020
(In Millions)
Entergy$88 $74 
Entergy Arkansas$8 $8 
Entergy Louisiana$33 $31 
Entergy New Orleans$1 $6 
Entergy Texas$28 $29 
System Energy$18 $— 

In addition to the protected and unprotected excess ADIT amounts, the net regulatory liability for income taxes includes other regulatory assets and liabilities for income taxes associated with AFUDC, which is described in Note 1 to the financial statements.
Included in the effect of the computation of the changes in deferred tax assets and liabilities is the recognition threshold and measurement of uncertain tax positions resulting in unrecognized tax benefits. The final economic outcome of such unrecognized tax benefits is generally the result of a negotiated settlement with the IRS that often differs from the amount that is recorded as realizable under GAAP. The intrinsic uncertainty with respect to all such tax positions means that the difference between current estimates of such amounts likely to be realized and actual amounts realized upon settlement may have an effect on income tax expense and the regulatory liability for income taxes in future periods.

Entergy anticipates that the effect of TCJA may continue to have ramifications that require adjustments in the future as certain events occur. These events include: 1) IRS audit adjustments to or amendments of federal and state income tax returns that include modifications to the computation of taxable income resulting from TCJA; and 2) additional guidance, interpretations, or rulings by the U.S. Department of the Treasury or the IRS. The potential exists for these types of events to result in future tax expense adjustments because of the difference in the federal corporate income tax rate between past and future periods and the effect of the tax rate change on ratemaking. In turn, these events also could potentially affect the regulatory liability for income taxes.

Coronavirus Aid, Relief, and Economic Security Act

In response to the economic impacts of the COVID-19 pandemic, President Trump signed the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) into law on March 27, 2020. The CARES Act provisions that result in the most significant opportunities for tax relief to Entergy and the Registrant Subsidiaries are (i) permitting a five-year carryback of 2018-2020 NOLs, (ii) removing the 80 percent limitation on NOLs carried to tax years beginning before 2021, (iii) increasing the limitation on interest expense deductibility for 2019 and 2020, (iv) accelerating available refunds for minimum tax credit carryforwards, modifying limitations on charitable contributions during 2020, and (v) delaying the payment of employer payroll taxes. Entergy deferred approximately $64 million of 2020 payroll tax payments, payable in equal installments over two years. The initial installment of $32 million was paid in December 2021. The second installment will be paid in December 2022.

Entergy Wholesale Commodities Restructuring

In the fourth quarter 2019, two separate events occurred resulting in a reduction of tax expense of $174 million. In November 2019 an Entergy Wholesale Commodities subsidiary recognized a reduction in income tax expense of $18 million in connection with the accounting method on power contracts associated with the Palisades nuclear power station. Additionally, Entergy’s ownership of Indian Point 2 and Indian Point 3 was restructured. The restructuring required Entergy to recognize Indian Point 2 and Indian Point 3 nuclear decommissioning liabilities for income tax purposes resulting in a tax accounting permanent difference that reduced income tax expense, net of unrecognized tax benefits, by $156 million. The accrual of the nuclear decommissioning liabilities also required Entergy to recognize a gain for income tax purposes, a portion of which resulted in an increase in the tax basis of the assets. Recognition of the gain and the increase in the tax basis of the assets represents a tax accounting temporary difference.

Immediately prior to the restructuring, through its ownership of Indian Point 2 and Indian Point 3, Entergy donated property to Stony Brook University and recognized an associated tax deduction resulting in a decrease to tax expense of $19 million.

In the fourth quarter 2020, Entergy’s ownership of Palisades was restructured. The restructuring required Entergy to recognize Palisades’ nuclear decommissioning liability for income tax purposes resulting in a tax accounting permanent difference that reduced income tax expense, net of unrecognized tax benefits, by $9.2 million. The accrual of the nuclear decommissioning liability also required Entergy to recognize a gain for income tax purposes, a portion of which resulted in an increase in the tax basis of the assets. Recognition of the gain and the increase in the tax basis of the assets represents a tax accounting temporary difference.
Tax Accounting Methods

In the fourth quarter 2015, System Energy and Entergy Louisiana adopted a new method of accounting for income tax return purposes in which their nuclear decommissioning costs will be treated as production costs of electricity includable in cost of goods sold. The new method resulted in a reduction of taxable income of $1.2 billion for System Energy and $2.2 billion for Energy Louisiana.

In conjunction with the 2014-2015 IRS audit discussed above, the IRS issued proposed adjustments concerning the nuclear decommissioning tax position allowing System Energy to include $102 million of its decommissioning liability in cost of goods sold, and Entergy Louisiana to include $221 million of its decommissioning liability in cost of goods sold. Entergy, System Energy, and Entergy Louisiana agreed to the proposed adjustments included in the RAR.

As a result of System Energy being allowed to include part of its decommissioning liability in cost of goods sold, System Energy and Entergy recorded a deferred tax liability of $26 million. System Energy also recorded federal and state taxes payable of $402 million. However, on a consolidated basis, Entergy utilized tax loss carryovers to offset the federal taxable income adjustment and did not record federal taxes payable as a result of the outcome of this uncertain tax position.

As a result of Entergy Louisiana being allowed to include part of its decommissioning liability in cost of goods sold, Entergy Louisiana and Entergy recorded a deferred tax liability of $60 million. Both Entergy Louisiana and Entergy utilized tax loss carryovers to offset the taxable income adjustment and accordingly did not record taxes payable as a result of the outcome of this uncertain tax position.

The partial disallowance of this uncertain tax position to include the decommissioning liability in cost of goods sold resulted in a $1.5 billion decrease in the balance of unrecognized tax benefits related to federal and state taxes for Entergy. Additionally, both System Energy and Entergy Louisiana recorded a reduction to their balances of unrecognized tax benefits for federal and state taxes of $461 million and $1.1 billion, respectively.

Entergy Arkansas adopted the same method of accounting for its nuclear decommissioning costs which resulted in a $1.8 billion reduction in taxable income on its 2018 tax return.

In 2016, Entergy Louisiana elected mark-to-market income tax treatment for various wholesale electric power purchase and sale agreements, including Entergy Louisiana’s contract to purchase electricity from the Vidalia hydroelectric facility and from System Energy under the Unit Power Sales Agreement. The election resulted in a $2.2 billion deductible temporary difference. In 2017, Entergy New Orleans also elected mark-to-market income tax treatment for wholesale electric contracts which resulted in a $1.1 billion deductible temporary difference. In 2018, Entergy Arkansas and Entergy Mississippi accrued deductible temporary differences related to mark-to-market tax accounting for wholesale electric contracts of $2.1 billion and $1.9 billion, respectively. Additionally, in 2020, Entergy Texas elected mark-to-market income tax treatment for wholesale electric power purchase and sale agreements which resulted in a $2.5 billion deductible temporary difference.

Arkansas and Louisiana Corporate Income Tax Rate Changes

In April 2019 and December 2021 the State of Arkansas enacted corporate income tax law changes that phased in rate reductions from the former rate of 6.5% to 6.2% in 2021, 5.9% in 2022, and 5.7% in 2023.    As a result of the 2019 rate reduction, Entergy Arkansas computed a regulatory liability for income taxes as of December 31, 2020 of approximately $21 million, which includes a tax gross-up related to the treatment of income taxes in the retail and wholesale ratemaking formulas and has been included in the appropriate rate mechanisms. Entergy Arkansas recorded an incremental regulatory liability of $11 million associated with the rate reduction enacted in December 2021. The Arkansas tax law enactment also phases in an increase to the net operating loss carryover period from five to ten years.
Pursuant to legislation enacted in 2021 and approved by Louisiana citizens by amendment to the state constitution, beginning January 1, 2022, federal income taxes paid will no longer be deductible for state income tax purposes, and the top Louisiana corporate income tax rate will be reduced from 8% to 7.5%. As a result of this change in Louisiana tax law, the Louisiana applicable tax rate increased by 0.85%. Accordingly, deferred tax assets and liabilities were adjusted to reflect the new applicable federal and state rates. Legislation enacted in 2021 also provides that Louisiana net operating losses generally have an indefinite carryover period.

Entergy recorded a net increase to its deferred tax asset of $27 million. Entergy Louisiana and Entergy New Orleans recorded net increases to their deferred tax liabilities before consideration of the tax gross-up of $77 million and $8 million, respectively, which were offset by regulatory assets for income taxes. Therefore, these increases had no effect on tax expense. However, the increase of deferred tax assets associated with certain assets reduced tax expense for Entergy Louisiana and Entergy New Orleans by $6 million and $2 million, respectively.

Consolidated Income Tax Return of Entergy Corporation

In September 2019, Entergy Utility Holding Company, LLC and its regulated, wholly-owned subsidiaries including Entergy Arkansas, Entergy Louisiana, Entergy Mississippi, and Entergy New Orleans, became eligible to and joined the Entergy Corporation consolidated federal income tax group.  As a result of these four Utility operating companies re-joining the Entergy Corporation consolidated tax return group, Entergy was able to recognize a $41 million deferred tax asset associated with a previously unrecognized net operating loss carryover.

In September 2019, Entergy Texas issued $35 million of 5.375% Series A preferred stock with a liquidation value of $25 per share resulting in the disaffiliation and de-consolidation of Entergy Texas from the consolidated federal income tax return of Entergy Corporation.  These changes will not affect the accrual or allocation of income taxes for the Registrant Subsidiaries. See Note 6 to the financial statements for discussion of the preferred stock issuance.

Vermont Yankee

The Vermont Yankee transaction resulted in Entergy generating a net deferred tax asset in January 2019.  The deferred tax asset could not be fully realized by Entergy in the first quarter 2019; accordingly, Entergy accrued a net tax expense of $29 million on the disposition of Vermont Yankee. See Note 14 to the financial statements for discussion of the Vermont Yankee transaction.

Stock Compensation

In accordance with stock compensation accounting rules, Entergy and the Registrant Subsidiaries recognized excess tax deductions as a reduction of income tax expense in the first quarter 2020. Due to the vesting and exercise of certain Entergy stock-based awards, Entergy recorded a permanent tax reduction of approximately $24.7 million, including $4.8 million for Entergy Arkansas, $8.6 million for Entergy Louisiana, $2.7 million for Entergy Mississippi, $1.5 million for Entergy New Orleans, $2.7 million for Entergy Texas, and $1.3 million for System Energy.