(13) Related Party Transactions

Icahn Enterprises

The following is a summary of dividends paid to the Company’s stockholders, including IEP, for the respective quarters to which the distributions relate:



(In millions, except per share data)	December 31, 2017		March 31, 2018		June 30, 2018		Total Dividends Paid in 2018
Amount paid to IEP	$	36	$	36	$	53	$	125
Amount paid to public stockholders	7		8		22		37
Total amount paid	$	43	$	44	$	75	$	162

Per common share	$	0.50	$	0.50	$	0.75	$	1.75
Shares outstanding (in millions)	86.8		86.8		100.6

CVR Refining has made distributions to IEP of $10 million for the nine months ended September 30, 2018 relating to the three preceding quarters.

Activity associated with the Company’s related party arrangements for the three and nine month periods ended September 30, 2018 and 2017 is summarized below:



Expenses with related parties
	Three Months Ended September 30,				Nine Months Ended September 30,
(in millions)	2018		2017		2018		2017
Cost of materials and other
Railcar Lease Agreements and Maintenance:
ARI Leasing, LLC	$	—	$	—	$	1	$	1

Payments made
Insight Portfolio Group	—		—		—		—
Tax Allocation Agreement:
American Entertainment Properties Corporation	$	5	$	—	$	13	$	10



Amounts due to/from related parties
(in millions)	September 30, 2018		December 31, 2017
Accounts Receivable (Payable)
Tax Allocation Agreement:
American Entertainment Properties Corporation (“AEPC”)	$	—	$	5

Tax Allocation Agreement

CVR has been a member of the consolidated federal tax group of American Entertainment Properties Corporation (“AEPC”), an affiliate of IEP, and party to a tax allocation agreement with AEPC (the “Tax Allocation Agreement”). The Tax Allocation Agreement provides that AEPC will pay all consolidated federal income taxes on behalf of the consolidated tax group. CVR is required to make payments to AEPC in an amount equal to the tax liability, if any, that it would have paid if it were to file as a consolidated group separate and apart from AEPC.

As a result of the exchange offer discussed in Note 1, AEPC’s ownership of CVR has been reduced below 80% and CVR is no longer eligible to file as a member of the AEPC consolidated federal income tax group subsequent to the exchange. Beginning with the tax period after the exchange, CVR will become the parent of a new consolidated group for U.S. federal income tax purposes, and will file and pay its federal income tax obligations directly with the IRS. Pursuant to the terms of the Tax Allocation Agreement, however, CVR may be required to make payments in respect of taxes owed by AEPC for periods prior to the exchange. Similar principles may apply for state or local income tax purposes where CVR filed combined, consolidated or unitary tax returns with AEPC.