|
Taxes on Income (Tables)
|
12 Months Ended |
|
Dec. 31, 2011
|
| Schedule of Income from Continuing Operations Before Provision for Taxes on Income |
The components
of Income from continuing operations before provision for taxes
on income follow:
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| |
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|
YEAR ENDED DECEMBER 31,
|
|
|
(MILLIONS OF
DOLLARS) |
|
2011 |
|
|
2010 |
|
|
2009 |
|
|
United States
|
|
$ |
(2,254) |
|
|
$ |
(2,513) |
|
|
$ |
(3,694) |
|
|
International
|
|
|
15,016 |
|
|
|
11,795 |
|
|
|
14,368 |
|
|
Income from continuing operations
before provision for taxes on income(a),
(b)
|
|
$ |
12,762 |
|
|
$ |
9,282 |
|
|
$ |
10,674 |
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| |
|
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|
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|
|
|
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| (a) |
2011 vs.
2010 – The decrease in the domestic loss was primarily due to
the non-recurrence of a charge of $1.3 billion (pre-tax) in 2010
for asbestos litigation related to our wholly owned subsidiary,
Quigley Company, Inc., partially offset by a reduction in revenues
due to the loss of exclusivity for several biopharmaceutical
products and the impact of the U.S. Healthcare Legislation. The
increase in international income was due to the favorable impact of
foreign exchange, higher impairment charges in 2010, as well as
increased revenues from the biopharmaceutical products such as the
Prevnar/Prevenar franchise, Enbrel and Celebrex.
|
| (b) |
2010 vs.
2009 – The decrease in the domestic loss was due to revenues
from legacy Wyeth products and a reduction in domestic
restructuring charges partially offset by increased amortization
charges primarily related to identifiable intangibles in connection
with our acquisition of Wyeth and litigation charges primarily
related to our wholly owned subsidiary Quigley Company, Inc. The
decrease in international income was due primarily to an increase
in international restructuring and amortization charges plus the
non-recurrence of the gain in 2009 in connection with the formation
of ViiV, partially offset by revenues from legacy Wyeth
products.
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|
| Schedule of Provision for Taxes on Income |
|
The components of
Provision for taxes on income based on the location of the
taxing authorities, follow: |
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YEAR ENDED DECEMBER 31,
|
|
|
(MILLIONS OF
DOLLARS) |
|
2011 |
|
|
2010 |
|
|
2009 |
|
|
United States:
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Current income taxes:
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Federal
|
|
$ |
1,349 |
|
|
$ |
(2,763 |
) |
|
$ |
10,151 |
|
|
State and local
|
|
|
208 |
|
|
|
(315 |
) |
|
|
68 |
|
|
Deferred income taxes:
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Federal
|
|
|
349 |
|
|
|
2,010 |
|
|
|
(10,005 |
) |
|
State and local
|
|
|
(242 |
) |
|
|
(6 |
) |
|
|
(93 |
) |
|
Total U.S. tax
provision/(benefit)(a),
(b), (c)
|
|
|
1,664 |
|
|
|
(1,074 |
) |
|
|
121 |
|
|
International:
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|
|
|
|
|
|
|
|
|
|
|
|
|
Current income taxes
|
|
|
2,202 |
|
|
|
2,212 |
|
|
|
1,516 |
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|
Deferred income taxes
|
|
|
157 |
|
|
|
(67 |
) |
|
|
508 |
|
|
Total international tax
provision
|
|
|
2,359 |
|
|
|
2,145 |
|
|
|
2,024 |
|
|
Provision for taxes on
income(d)
|
|
$ |
4,023 |
|
|
$ |
1,071 |
|
|
$ |
2,145 |
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| |
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| (a) |
In 2011,
the Federal deferred income tax expense includes approximately $2.1
billion as a result of providing U.S. deferred income taxes on
certain current-year funds earned outside of the U.S. that will not
be permanently reinvested overseas. (See Note 5C. Taxes on
Income: Deferred Taxes.)
|
| (b) |
In 2010,
the Federal current income tax benefit is primarily due to the tax
benefit recorded in connection with our $1.4 billion settlement
with the U.S. Internal Revenue Service and the reversal of $600
million of accruals related to interest on these unrecognized tax
benefits. (See below). The Federal deferred income tax expense
includes approximately $2.5 billion as a result of providing U.S.
deferred income taxes on certain current-year funds earned outside
of the U.S. that will not be permanently reinvested overseas. (See
Note 5C. Taxes on Income: Deferred Taxes).
|
| (c) |
In 2009,
virtually all of the Federal current income tax expense was due to
increased tax costs associated with certain business decisions
executed to finance the Wyeth acquisition, including the decision
to repatriate certain funds earned outside of the U.S. In addition,
virtually all of the Federal deferred income tax benefit was due to
a reduction of deferred tax liabilities recorded in connection with
our acquisition of Wyeth. (See Note 2A. Acquisitions,
Divestitures, Collaborative Arrangements and Equity-Method
Investments: Acquisition of Wyeth).
|
| (d) |
In 2011,
federal, state and international net tax liabilities assumed or
established on the date of the acquisition primarily of King are
excluded. In 2010 and 2009, federal, state and international net
tax liabilities assumed or established on the date of the
acquisition primarily of Wyeth are excluded. (See Note 2A.
Acquisitions, Divestitures, Collaborative Arrangements and
Equity-Method Investments: Acquisition of Wyeth and Note 2B.
Acquisitions, Divestitures, Collaborative Arrangements and
Equity-Method Investments: Acquisition of King Pharmaceuticals,
Inc.)
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|
| Reconciliation of the U.S. Statutory Income Tax Rate to the Effective Tax Rate for Income from Continuing Operations |
The
reconciliation of the U.S. statutory income tax rate to our
effective tax rate for Income from continuing operations
follows:
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|
0000000000000 |
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|
0000000000000 |
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|
0000000000000 |
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|
YEAR ENDED DECEMBER 31, |
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| |
|
2011 |
|
|
2010 |
|
|
2009 |
|
|
|
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|
U.S. statutory income tax
rate
|
|
|
35.0% |
|
|
|
35.0% |
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|
|
35.0% |
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Taxation of non-U.S. operations
(a)
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(3.3) |
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2.2 |
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(9.4) |
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Resolution of certain tax
positions(b)
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(2.7) |
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(26.4) |
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— |
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Sales of biopharmaceutical
companies(c)
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|
0.2 |
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|
— |
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(5.1) |
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U.S. Healthcare
Legislation(c)
|
|
|
0.7 |
|
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|
2.8 |
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|
— |
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U.S. research tax credit and
manufacturing deduction
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(0.9) |
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(2.3) |
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(1.3) |
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Legal settlements(c)
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— |
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0.4 |
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(1.6) |
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Acquired IPR&D(d)
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— |
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0.5 |
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0.2 |
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Wyeth acquisition-related
costs(c)
|
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|
— |
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0.5 |
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2.4 |
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All other—net
|
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2.5 |
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(1.2) |
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(0.1) |
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Effective tax rate for income from
continuing operations
|
|
|
31.5% |
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|
11.5% |
|
|
|
20.1% |
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| (a) |
For
taxation of non-U.S. operations, this rate impact reflects the fact
that we operate manufacturing subsidiaries in Puerto Rico, Ireland,
and Singapore. We benefit from a Puerto Rican incentive grant that
expires in 2029. Under the grant, we are partially exempt from
income, property and municipal taxes. In Ireland, we benefited from
an incentive tax rate effective through 2010 on income from
manufacturing operations. In Singapore, we benefit from incentive
tax rates effective through 2031 on income from manufacturing
operations. The rate impact also reflects the jurisdictional
location of earnings, the costs of certain repatriation decisions
and uncertain tax positions.
|
| (b) |
For a
discussion about the resolution of certain tax positions, see
Note 5D. Taxes on Income: Tax Contingencies.
|
| (c) |
For a
discussion about the sales of the biopharmaceutical companies, the
impact of U.S. Healthcare Legislation, legal settlements and Wyeth
acquisition related costs, see Note 5A. Taxes on Income: Taxes
on Income.
|
| (d) |
The
charges for acquired IPR&D are primarily not deductible for tax
purposes.
|
|
| Schedule of Deferred Tax Assets and Liabilities Before Jurisdictional Netting |
The components
of our deferred tax assets and liabilities, shown before
jurisdictional netting follow:
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| |
|
2011 DEFERRED TAX |
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|
2010 DEFERRED TAX |
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| (MILLIONS OF DOLLARS) |
|
ASSETS |
|
|
(LIABILITIES) |
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|
ASSETS |
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|
(LIABILITIES) |
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Prepaid/deferred items
|
|
$ |
1,611 |
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$ (211) |
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$ |
1,321 |
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|
$ (112) |
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Inventories
|
|
|
324 |
|
|
|
(52 |
) |
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|
132 |
|
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(59) |
|
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Intangibles
|
|
|
1,713 |
|
|
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(16,014 |
) |
|
|
1,165 |
|
|
|
(17,104) |
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Property, plant and
equipment
|
|
|
226 |
|
|
|
(1,326 |
) |
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|
420 |
|
|
|
(2,146) |
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Employee benefits
|
|
|
4,285 |
|
|
|
(524 |
) |
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|
4,479 |
|
|
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(56) |
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Restructurings and other
charges
|
|
|
554 |
|
|
|
(95 |
) |
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|
1,359 |
|
|
|
(70) |
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Legal and product liability
reserves
|
|
|
1,812 |
|
|
|
— |
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|
|
1,411 |
|
|
|
— |
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Net operating loss/credit
carryforwards
|
|
|
4,414 |
|
|
|
— |
|
|
|
4,575 |
|
|
|
— |
|
|
Unremitted earnings
|
|
|
— |
|
|
|
(11,699 |
) |
|
|
— |
|
|
|
(9,524) |
|
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State and local tax
adjustments
|
|
|
476 |
|
|
|
— |
|
|
|
452 |
|
|
|
— |
|
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All other
|
|
|
1,197 |
|
|
|
(125 |
) |
|
|
601 |
|
|
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(554) |
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Subtotal
|
|
|
16,612 |
|
|
|
(30,046 |
) |
|
|
15,915 |
|
|
|
(29,625) |
|
|
Valuation allowance
|
|
|
(1,201 |
) |
|
|
— |
|
|
|
(894 |
) |
|
|
— |
|
|
|
|
|
Total deferred taxes
|
|
$ |
15,411 |
|
|
|
$(30,046) |
|
|
$ |
15,021 |
|
|
|
$(29,625) |
|
|
|
|
|
Net deferred tax liability(a),(b)
|
|
|
|
|
|
|
$(14,635) |
|
|
|
|
|
|
|
$(14,604) |
|
|
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| (a) |
2011 vs.
2010 – The net deferred tax liability position in 2011 was
about the same as 2010 and reflects an increase in noncurrent
deferred tax liabilities related to intangibles established in
connection with our acquisition of King and an increase in
noncurrent deferred tax liabilities on unremitted earnings,
partially offset by the reduction in noncurrent deferred tax
liabilities related to the amortization of identifiable
intangibles, and an increase in current deferred tax assets
established as a result of litigation charges related to hormone
therapy.
|
| (b) |
In 2011,
included in Taxes and other current assets ($4.0 billion),
Taxes and other noncurrent assets ($1.2 billion), Other
current liabilities ($291 million) and Noncurrent deferred
tax liabilities ($19.6 billion). In 2010, included in Taxes
and other current assets ($3.0 billion), Taxes and other
noncurrent assets ($1.2 billion), Other current
liabilities ($108 million) and Noncurrent deferred tax
liabilities ($18.6 billion).
|
|
| Reconciliation of the Beginning and Ending Amounts of Gross Unrecognized Tax Benefits |
The
reconciliation of the beginning and ending amounts of gross
unrecognized tax benefits follows:
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|
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|
|
|
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|
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|
| (MILLIONS OF DOLLARS) |
|
2011 |
|
|
|
|
2010 |
|
|
|
|
2009 |
|
|
|
|
|
Balance, January 1
|
|
$ |
(6,759 |
) |
|
|
|
|
$(7,657) |
|
|
|
|
|
$(5,372) |
|
|
Acquisitions(a)
|
|
|
(72 |
) |
|
|
|
|
(49) |
|
|
|
|
|
(1,785) |
|
|
Increases based on tax positions
taken during a prior period(b)
|
|
|
(502 |
) |
|
|
|
|
(513) |
|
|
|
|
|
(79) |
|
|
Decreases based on tax positions
taken during a prior period(b),
(c)
|
|
|
271 |
|
|
|
|
|
2,384 |
|
|
|
|
|
38 |
|
|
Decreases based on cash payments for
a prior period
|
|
|
575 |
|
|
|
|
|
280 |
|
|
|
|
|
— |
|
|
Increases based on tax positions
taken during the current period(b)
|
|
|
(855 |
) |
|
|
|
|
(1,396) |
|
|
|
|
|
(941) |
|
|
Decreases based on tax positions
taken during the current period
|
|
|
— |
|
|
|
|
|
— |
|
|
|
|
|
712 |
|
|
Impact of foreign exchange
|
|
|
(89 |
) |
|
|
|
|
104 |
|
|
|
|
|
(284) |
|
|
Other, net(d)
|
|
|
122 |
|
|
|
|
|
88 |
|
|
|
|
|
54 |
|
|
|
|
|
Balance, December 31(e)
|
|
$ |
(7,309 |
) |
|
|
|
|
$(6,759) |
|
|
|
|
|
$(7,657) |
|
|
|
|
| (a) |
The
amount in 2011 primarily relates to the acquisition of King and the
amounts in 2010 and 2009 primarily relate to the acquisition of
Wyeth.
|
| (b) |
Primarily
included in Provision for taxes on income.
|
| (c) |
In 2011,
2010, and 2009, the decreases are primarily a result of effectively
settling certain issues with the U.S. and foreign tax authorities.
See discussions below.
|
| (d) |
Primarily
includes decreases as a result of a lapse of applicable statutes of
limitations.
|
| (e) |
In 2011,
included in Income taxes payable ($357 million), Taxes
and other current assets ($11 million), Taxes and other
noncurrent assets ($225 million), Noncurrent deferred tax
liabilities ($677 million) and Other taxes payable ($6.0
billion). In 2010, included in Income taxes payable ($421
million), Taxes and other current assets ($279 million),
Taxes and other noncurrent assets ($169 million),
Noncurrent deferred tax liabilities ($369 million) and
Other taxes payable ($5.5 billion).
|
|