Please provide us with the analyses that you performed in formulating your
disclosure, including the effective rates, amounts by nature, and calculations.
Please also clarify how the amount of taxes paid in Qatar were considered relative
to the disclosure threshold in determining that these would not be shown in the
table on page 106, and address the requirement in FASB ASC 740-10-50-12C, to
discuss “the nature, effect, and underlying causes” of the reconciling items
identified within your reconciliation.
Response:
In preparing our 2025 effective income tax rate reconciliation, management evaluated foreign
jurisdictional tax impacts in accordance with ASC 740‑10‑50‑12, including both individual
country effects and offsetting items, to determine whether any reconciling item exceeded the
5% quantitative disclosure threshold. For clarity, we calculated the 5% threshold to equal $433
million. This was based on 5% of our theoretical U.S. federal statutory tax of $8.666 billion, as
reported in our reconciliation on page 105 of our Form 10-K.
The Staff’s comment notes that the amount of income taxes paid in Canada and Guyana, as
reported on page 106 of our Form 10-K, may suggest rate differentials that exceed the
disclosure threshold. We would like to clarify that management does not use taxes paid as a
proxy for effective tax rates when evaluating rate reconciliation disclosures under ASC 740.
Our determination of whether a jurisdiction exceeded the 5% disclosure threshold was based
on income tax expense and effective tax rate impacts, not tax payments.
For both Canada and Guyana, the absolute amount of income tax expense arising from each
jurisdiction did exceed $433 million. However, merely having tax expense that exceeds the
threshold does not trigger disclosure. Instead, the disclosure provisions of ASC 740-10-50-12A
require that a foreign jurisdiction be separately disclosed when the difference between (i) the
pretax results for that jurisdiction taxed at the jurisdiction’s tax rate, and (ii) the pretax results
for that jurisdiction taxed at the U.S. statutory federal corporate rate of 21%, exceeds the 5%
threshold; in our case, that difference would have to exceed $433 million. We confirm that the
magnitude of the difference in each of Canada’s and Guyana’s tax rates relative to the 21%
U.S. statutory rate did not exceed the $433 million disclosure threshold for separate
presentation noted above.
Accordingly, the effects of these jurisdictions were aggregated and presented within the “All
other countries” reconciling line on page 105. We confirm that no individual reconciling item for
either country, whether gross or net of offsetting effects, exceeded the applicable quantitative
threshold that would require separate disclosure.
The Staff also asked how taxes paid in Qatar were considered relative to the disclosure
threshold and why they were not included in the table of income taxes paid on page 106.
Our interests in Qatar are held through equity method investments, not consolidated entities.
The equity method investee, not ExxonMobil, is responsible for paying the income tax
associated with the equity method earnings reported in our financial statements. Accordingly,
consistent with ASC 740 and the income taxes paid disclosure requirements, we limit our
income tax payment disclosures to those entities which we consolidate. For these reasons,
taxes paid in Qatar were appropriately excluded from the table on page 106, and their