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Income Taxes

12 Months Ended

Dec. 31, 2024

Income Taxes

Income Taxes

16. Income Taxes

The difference between the book basis and the tax basis of our net assets, not directly subject to income taxes, is as follows:

​

​	​	​	​	​	​	​
​	​	Icahn Enterprises
​	​	December 31,
​		2024			2023
​		​	(in millions)
Book basis of net assets	​	$	2,449	​	$	3,224
Book/tax basis difference	​		(366)	​		(540)
Tax basis of net assets	​	$	2,083	​	$	2,684

​

Income (loss) from continuing operations before income tax benefit (expense) is as follows:

​

​	​	​	​	​	​	​	​	​	​
​	​	Year Ended December 31,
​		2024			2023			2022
​	​	(in millions)
Domestic	​	$	(570)	​	$	(943)	​	$	(8)
International	​		3	​		21	​		17
​	​	$	(567)	​	$	(922)	​	$	9

​

Income tax benefit (expense) attributable to continuing operations is as follows:

​

​	​	​	​	​	​	​	​	​	​
​	​	Year Ended December 31,
​		2024			2023			2022
​	​	(in millions)
Current:	​	​		​	​		​	​
Domestic	​	$	(20)	​	$	(130)	​	$	(174)
International	​		9	​		(8)	​		(8)
Total current	​		(11)	​		(138)	​		(182)
Deferred:	​			​			​
Domestic	​		43	​		41	​		149
International	​		(7)	​		7	​		(1)
Total deferred	​		36	​		48	​		148
​	​	$	25	​	$	(90)	​	$	(34)

​

A reconciliation of the income tax benefit (expense) calculated at the federal statutory rate to income tax benefit (expense) on continuing operations as shown in the consolidated statements of operations is as follows:

​

​	​	​	​	​	​	​	​	​	​
​	​	Year Ended December 31,
​		2024			2023			2022
​	​	(in millions)
Income tax benefit at U.S. statutory rate	​	$	119	​	$	193	​	$	(2)
Tax effect from:	​			​			​
Valuation allowance	​		(68)	​		(1)	​		100
Non-controlling interest	​		8	​		23	​		38
Credits and incentives	​	​	19	​	​	26	​	​	—
Uncertain tax positions	​	​	5	​	​	17	​	​	—
Deconsolidation	​	​	—	​	​	23	​	​	—
Tax gain not on books	​	​	—	​	​	(83)	​	​	—
Dividends received	​		(4)	​		(20)	​		(23)
Income not subject to taxation	​		(91)	​		(239)	​		(88)
State taxes	​		32	​		(26)	​		(49)
Other	​		5	​		(3)	​		(10)
Income tax benefit (expense)	​	$	25	​	$	(90)	​	$	(34)

​

The tax effect of significant differences representing deferred tax assets (liabilities) (the difference between financial statement carrying value and the tax basis of assets and liabilities) is as follows:

​

​	​	​	​	​	​	​
​	​	December 31,
​		2024			2023
​	​	(in millions)
Deferred tax assets:		​		​	​
Contingent liabilities	​	$	56	​	$	61
Net operating loss	​		962	​		954
Tax credits	​		54	​		48
Capital loss	​		241	​		200
Leases	​		132	​		139
Investment in partnerships	​	​	135	​	​	147
Other	​		87	​		105
Total deferred tax assets	​		1,667	​		1,654
Less: Valuation allowance	​		(908)	​		(860)
Net deferred tax assets	​	$	759	​	$	794
​	​	​	​	​	​	​
Deferred tax liabilities:	​			​
Property, plant and equipment	​	$	(364)	​	$	(408)
Intangible assets	​		(60)	​		(65)
Investment in partnerships	​		(161)	​		(180)
Investment in U.S. subsidiaries	​		(163)	​		(163)
Leases	​		(129)	​		(135)
Other	​		(53)	​		(58)
Total deferred tax liabilities	​		(930)	​		(1,009)
​	​	$	(171)	​	$	(215)

​

We recorded deferred tax assets and deferred tax liabilities of $160 million and $331 million, respectively, as of December 31, 2024 and $184 million and $399 million, respectively, as of December 31, 2023.

We analyze all positive and negative evidence to consider whether it is more likely than not that all of the deferred tax assets will be realized. Projected future income, tax planning strategies and the expected reversal of deferred tax liabilities are considered in making this assessment. As of December 31, 2024 we had a valuation allowance of approximately $908 million primarily related to tax loss and credit carryforwards and other deferred tax assets. The current and future provisions for income taxes may be significantly impacted by changes to valuation allowances. These allowances will be maintained until it is more likely than not that the deferred tax assets will be realized. For the year ended December 31, 2024, the valuation allowance on deferred tax assets increased $48 million. The increase was primarily attributable to increases in capital loss carryforwards and state net operating loss carryforwards.

At December 31, 2024, American Entertainment Properties Corp. (“AEPC”), a wholly-owned corporate subsidiary of Icahn Enterprises, which includes all or parts of our Automotive, Food Packaging, Pharma, Home Fashion and Real Estate segments had U.S. federal net operating loss carryforwards of approximately $3.1 billion with expiration dates from 2024 through unlimited carryforward periods. Additionally, AEPC and its corporate subsidiaries had foreign net operating loss carryforwards of $16 million with an unlimited carryforward period.

At December 31, 2024, CVR Energy had state income tax credits of $22 million, which are available to reduce future state income taxes. These credits, if not used, will begin expiring in 2040.

As of December 31, 2024, we have not provided taxes on approximately $140 million of undistributed earnings in foreign subsidiaries which are deemed to be indefinitely reinvested. If at some future date these earnings cease to be permanently reinvested, we may be subject to foreign income and withholding taxes upon repatriation of such amounts. An estimate of the tax liability that would be incurred upon repatriation of foreign earnings is not practicable to determine.

Accounting for Uncertainty in Income Taxes

A summary of the changes in the gross amounts of unrecognized tax benefits for the years ended December 31, 2024, 2023 and 2022 are as follows:

​

​	​	​	​	​	​	​	​	​	​
​	​	Year Ended December 31,
​		2024			2023			2022
​	​	(in millions)
Balance at January 1	​	$	10	​	$	27	​	$	33
Addition based on tax positions related to the current year	​		—	​		—	​		—
Increase for tax positions of prior years	​		—	​		—	​		—
Decrease for tax positions of prior years	​		—	​		—	​		—
Decrease for statute of limitation expiration	​		(1)	​		(17)	​		(6)
Balance at December 31	​	$	9	​	$	10	​	$	27

​

At December 31, 2024, 2023 and 2022, we had unrecognized tax benefits of $9 million, $10 million and $27 million, respectively. Of these totals, $3 million, $10 million and $25 million represent the amount of unrecognized tax benefits that if recognized, would affect the annual effective tax rate in the respective periods. The total unrecognized tax benefits differ from the amount which would affect the effective tax rate primarily due to the impact of valuation allowances.

During the next 12 months, we do not expect any amount of unrecognized tax benefits to be released.

We recognize interest and penalties accrued related to unrecognized tax benefits as a component of income tax expense. We recorded less than $1 million, $4 million and $6 million as of December 31, 2024, 2023 and 2022, respectively, in liabilities for tax related net interest and penalties in our consolidated balance sheets. Income tax expense (benefit) related to interest and penalties were $(4) million, $(2) million and $2 million for the years December 31, 2024, 2023 and 2022, respectively. We or certain of our subsidiaries file income tax returns in the U.S. federal jurisdiction, various state jurisdictions and various non-U.S. jurisdictions. We and our subsidiaries are no longer subject to U.S. federal tax examinations for years before 2020 or state and local examinations for years before 2019, with limited exceptions.

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- Definition

The entire disclosure for income taxes. Disclosures may include net deferred tax liability or asset recognized in an enterprise's statement of financial position, net change during the year in the total valuation allowance, approximate tax effect of each type of temporary difference and carryforward that gives rise to a significant portion of deferred tax liabilities and deferred tax assets, utilization of a tax carryback, and tax uncertainties information.

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