Annual report pursuant to Section 13 and 15(d)

Income Taxes

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Income Taxes
 12 Months Ended
Dec. 31, 2024
Income Tax Disclosure [Abstract]  
Income Taxes INCOME TAXES
The jurisdictional components of income before income taxes and non-controlling interests on our Consolidated Statements of Operations are as follows (in millions):
Year Ended December 31,
2024 2023 2022
U.S. $ 4,696  $ 11,176  $ (1,575)
International 607  3,402  4,669 
Total income before income taxes and non-controlling interests $ 5,303  $ 14,578  $ 3,094 
Income tax provision included in our reported net income consisted of the following (in millions): 
Year Ended December 31,
2024 2023 2022
Current:
Federal $ 471  $ 130  $ 6 
State 2  1  2 
Foreign 8  (1) 11 
Total current 481  130  19 
Deferred:
Federal 319  2,377  320 
State 9  15  118 
Foreign 2  (3) 2 
Total deferred 330  2,389  440 
Total income tax provision $ 811  $ 2,519  $ 459 
 
Our income tax rates do not bear a customary relationship to statutory income tax rates. A reconciliation of the federal statutory income tax rate of 21% to our effective income tax rate is as follows: 
Year Ended December 31,
2024 2023 2022
U.S. federal statutory tax rate 21.0  % 21.0  % 21.0  %
Income not taxable to Cheniere (5.0) (3.1) (8.2)
Foreign-derived intangible income deduction (1.0) (0.7) (1.2)
Valuation allowance (0.7) —  2.6 
Other 1.0  0.1  0.6 
Effective tax rate as reported 15.3  % 17.3  % 14.8  %
Significant components of our deferred tax assets and liabilities are as follows (in millions): 
December 31,
2024 2023
Deferred tax assets    
Net operating loss (“NOL”) carryforwards
Federal $ 313  $ 915 
State 119  163 
Tax Credits
CAMT carryforward 383  — 
Other tax credits 40  33 
Derivative instruments —  98 
Operating lease liabilities 562  550 
Other 306  298 
Less: valuation allowance (1) (110) (147)
Total deferred tax assets 1,613  1,910 
Deferred tax liabilities  
Investment in partnerships (305) (309)
Property, plant and equipment (2,459) (2,564)
Operating lease assets (548) (538)
Derivative instruments (108) — 
Other (30) (18)
Total deferred tax liabilities (3,450) (3,429)
Net deferred tax liabilities $ (1,837) $ (1,519)
(1)Valuation allowance primarily relates to state NOL carryforward deferred tax assets and decreased by $37 million during the year ended December 31, 2024 primarily due to the reduced Louisiana corporate tax rate beginning January 1, 2025. The valuation allowance increased by $4 million and $80 million during the years ended December 31, 2023 and 2022, respectively.

NOL and tax credit carryforwards

Louisiana enacted legislation during the fourth quarter of 2024 which reduced the corporate tax rate from 7.5% to 5.5% beginning in 2025. As a result of such legislation, we remeasured our Louisiana deferred tax assets and liabilities at year end, resulting in a $43 million reduction to our Louisiana net deferred tax assets and $38 million reduction to our valuation allowance.

As of December 31, 2024, we had federal and state NOL carryforwards of approximately $1.5 billion and $2.2 billion, respectively. All of our NOLs have an indefinite carryforward period.

As of December 31, 2024, our CAMT credit carryforward has an indefinite life and our other tax credits expire between 2028 and 2034.

Our NOL and tax credit carryforwards are not subject to, nor impacted by, any prior tax ownership change. We continue to monitor public trading activity in our shares to identify potential tax ownership changes that could impact our timing and ability to utilize such attributes.
Unrecognized Tax Benefits

As of December 31, 2024, we had unrecognized tax benefits of $72 million. If recognized, $65 million of unrecognized tax benefits would affect our effective tax rate in future periods. Interest and penalties related to income tax matters are recognized as part of income tax expense. Interest recognized as part of income tax provision was $6 million and $4 million as of December 31, 2024 and 2023, respectively, and cumulative accrued interest was $10 million and $4 million as of December 31, 2024 and 2023, respectively. There were no penalties associated with liabilities for unrecognized tax benefits recorded for the years ended December 31, 2024 and 2023. We do not expect the amount of our existing unrecognized tax benefit to significantly increase or decrease within the next 12 months.

We are subject to tax in the U.S. and various state and foreign jurisdictions and we are subject to periodic audits and reviews by taxing authorities. Federal and United Kingdom tax returns for the years after 2017 and state tax returns for the years after 2020 remain open for examination. Tax authorities may have the ability to review and adjust carryover attributes that were generated prior to these periods if utilized in an open tax year.

A reconciliation of the beginning and ending amounts of our unrecognized tax benefits is as follows (in millions): 
Year Ended December 31,
2024 2023
Balance at beginning of the year $ 73  $ 74 
Reductions for tax positions of prior years (1) (1)
Balance at end of the year $ 72  $ 73