RICHMOND, VA – May 22, 2012 – Altria
Group, Inc. (Altria) (NYSE: MO) today announced that it has executed a Closing
Agreement (Agreement) with the Internal Revenue Service (IRS) that, subject to
court approval, resolves the federal income tax treatment for all prior tax
years of certain leveraged lease transactions (referred to by the IRS as
lease-in/lease-out (LILO) and sale-in/lease-out (SILO) transactions) entered
into by Altria’s wholly-owned subsidiary, Philip Morris Capital Corporation
(PMCC).
Altria expects to pay approximately
$500 million in federal and state income taxes and related estimated interest
as a result of the Agreement. Of this amount, Altria expects to pay
approximately $450 million in federal income taxes and related estimated
interest with respect to the 2000 through 2010 tax years by the end of the
second quarter of 2012. The payment is net of federal income taxes that Altria
paid on gains associated with sales of assets leased in the LILO and SILO
transactions from January 1, 2008 through December 31, 2011. Of the $500
million, Altria also expects to pay approximately $50 million of state taxes
and related estimated interest. The tax component of these payments represents
an acceleration of federal and state income taxes that Altria would have
otherwise paid over the lease terms of the LILO and SILO transactions.
Pursuant to the Agreement, the IRS
will not assess against Altria any additional taxes or any penalties in any
open tax year through the 2010 tax year related to the LILO and SILO
transactions; nor will the IRS impose penalties with respect to any prior tax
years.
Altria also has agreed to dismiss,
with prejudice, the pending litigation in federal court related to the tax
treatment of the LILO and SILO transactions and to relinquish its right to seek
refunds for federal taxes and interest previously paid.
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