Federal Tax Reform. Agenda. Federal Tax Rate Decreases from 35% Impact of Federal tax reform. What is our deferred tax balance?

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1 Federal Tax Reform Presented by: Matthew Kahn Agenda Impact of Federal tax reform What is the impact of a lower Federal tax rate? How would expensing of capital affect our customer bills? How would the loss of interest deduction affect our customer bills? What is our deferred tax balance? What is the Day 1 impact? Federal Rate History Summary impacts Key takeaways 2 Federal Tax Rate s from 35% Overall, customer bills are lowered due to the lower tax rate and net income is unchanged Description Net Income Balance Sheet Customer Utility rates assume 35% tax rate; actual tax rate is 15% or 20% Tax expense lower Downward adjustment to tax expense No impact to cash regulatory liability for historical rates that customers were charged LOWER Overall, our customers own income tax expense. 3 1

2 Disallowance of Interest Deduction Customer bills are increased due to higher income taxes and net income is unchanged Disallowance of interest expense deduction on tax return Estimated Annual Impact Description Net Income Customer Treated as a nondeductible tax item (permanent) Tax expense increases Currently, tax deductibility lowers requirement tax expense No Impact on EPS, unless cash needs funded by equity HIGHER HIGHER 4 Impact of Tax Reform on Utility Customer Bills No Bonus Depreciation, Interest Expense Tax Deductible Impact on Customer Bill Possible Extension of Depreciable Lives of Plant Assets Rate Base Increase 5 Impact of Tax Reform on the Company No Bonus Depreciation, Interest Expense Tax Deductible Impact on The Company Possible Extension of Depreciable Lives of Plant Assets Rate Base Increase 6 2

3 Impact of Tax Reform on Utility Customer Bills 100% Bonus Depreciation, No Interest Expense Deduction Loss of Interest Expense Deduction Increased Depreciation Deduction Reduction to Rate Base Impact of Utility NOL Increase to Rate Base Impact on Customer Bill Impact of Reduced Borrowing Costs 7 Impact of Tax Reform on the Company 100% Bonus Depreciation, No Interest Expense Deduction Loss of Interest Expense Deduction Increased Depreciation Deduction Reduction to Rate Base Impact of Utility NOL Increase to Rate Base Impact on the Company Impact of Reduced Borrowing Costs 8 How Much Deferred Income Taxes Does Your Company Have on Its Books? Protected vs. Unprotected Return of excess deferred income taxes Timing Rate case factors State regulatory considerations Policy issues 9 3

4 Federal Rate History -- Corporate Tax Rates Tax Years Top Federal Rate % % % % % % 2017+?? 2% rate change amortized quickly Federal protected excess ADIT reversing under Average Rate Assumption Method (ARAM) 10 Approximate Impact on Cost of Service CECONY-Electric (amounts in 000 s) Total Federal Income Tax - Electric Excess DFIT Refunded over Remaining Life (45 Years) Interest Deduction Option* 100% Cap Ex Deduction* As filed in CECONY s recent rate case Adjusted for 15% - 20% Reduction in Federal Tax Expense (3) (3) (2) (2) Reduction in Revenue Requirement (4) (4) (3) (3) *Interest Deduction, assumes MACRS 100% Cap Ex Deduction, Interest non-deductible 11 Estimated Comparison of Regulated Companies DTL and ROE to 100% Capital Expensing under 15% & 20% Corporate Income Tax Rate Beginning 1/1/ ,000 $ (in Millions) 6,000 3,000 DTL under 100% Capital Expensing Earnings under 100% Capital Expensing DTL under Current Tax Law (35%) Earnings under Current Tax Law 1,500 Year 12 4

5 Key Takeaways Implications from Potential Federal Tax Reform Organized efforts (EEI plus industry members) to influence tax reform legislation, focusing on: Maintain parity between capital gains and dividend tax rates Maintain deduction for property taxes Interest deductibility/non-deductibility Accelerated depreciation deductibility Provide for a transition rule for a ratable return of excess deferred income taxes in the event of a significant tax rate reduction Will state jurisdictions follow federal tax deduction changes? 13 5