Amgen Inc. Framing the IRS Tax Dispute Ahead of the 2H+ Update

This report outlines the status of Amgen's ongoing multi-year tax dispute with the IRS concerning transfer pricing between its U.S. and Puerto Rican operations. Analysts estimate a total potential liability of $20 billion including interest and penalties.

Key Takeaways

• 1.Amgen is engaged in a multi-period IRS tax dispute concerning transfer pricing of profits between U.S. and Puerto Rican operations.
• 2.The combined potential liabilities across tax years 2010-2022 are estimated at approximately $20 billion including tax, penalties, and interest.

Table of Contents

• Summary of outstanding cases
• Tax Years 2010–2015
• Tax Years 2016–2022
• Status of the disputes
• Valuation and risks
• Disclosure Appendix