Why It Matters

Exelon is lobbying Congress over the corporate alternative minimum tax (CAMT), including H.R. 2872, the RESILIENCE Act of 2025, as the utility company pushes for changes to a tax that has increased costs for regulated utilities.

The CAMT was created by H.R. 5376, the Inflation Reduction Act of 2022, and generally imposes a 15 percent minimum tax based on the adjusted financial statement income of certain large corporations for taxable years beginning after Dec. 31, 2022.

Exelon's federal lobbying disclosures identify H.R. 2872, the RESILIENCE Act of 2025, and H.R. 5376, the Inflation Reduction Act of 2022, in connection with its lobbying on the corporate alternative minimum tax. The company has argued for changes affecting the treatment of repair and maintenance costs for regulated utilities.

By the Numbers

The company also retained external firms including OGR, Capitol Tax Partners LLP, BGR Government Affairs LLC, and Capitol Counsel LLC.

Exelon reported $460,000 in in-house lobbying expenses for the first quarter, then amended that filing in August to $530,000. The second-quarter filing showed $420,000, later amended to $500,000. Over the past four quarters, the company spent $4.31 million across all lobbying activities.

The Aug. 19 filings amended Exelon's recent lobbying disclosures.

The Agenda

The corporate alternative minimum tax has been a recurring focus of Exelon's tax lobbying. A first-quarter disclosure identified issues involving energy distribution and affordability and tax policy, including CAMT, and specifically listed H.R. 2872, the RESILIENCE Act of 2025. Other Exelon lobbying disclosures have identified H.R. 5376, the Inflation Reduction Act of 2022, in connection with CAMT.

The Inflation Reduction Act established the CAMT, which generally requires applicable corporations to pay the greater of their regular corporate income tax liability or a 15 percent tax calculated using adjusted financial statement income. Exelon and its utility subsidiaries have been subject to the CAMT since 2023.

Regulated utilities raised concerns because accounting rules can require certain repair and maintenance expenses to be capitalized and depreciated for financial statement purposes even when they are immediately deductible for regular tax purposes. IRS Notice 2025-49 provided limited relief for regulated operations, and subsequent Notice 2026-7 modified that guidance to permit adjustments for deductible repair and maintenance costs.

The newer guidance has already reduced Exelon's tax burden. Exelon said it amended its 2023 and 2024 federal tax returns after the February guidance, reducing its CAMT liability by $80 million. The company also received $235 million from Constellation under a tax matters agreement because the lower CAMT liability reduced Exelon's use of tax attributes originally generated by Constellation.

The RESILIENCE Act directly addresses the treatment of repair and maintenance expenditures under CAMT, making the legislation particularly relevant to regulated utilities such as Exelon.

Exelon has also maintained consistent engagement on Low Income Home Energy Assistance Program funding. Recent lobbying disclosures identify LIHEAP funding and legislation affecting the program among the company's federal budget priorities.

The Bottom Line

Exelon's lobbying on CAMT has coincided with Treasury and IRS changes that reduced the tax's impact on the company. The latest IRS guidance allows tax-deductible repair and maintenance expenses to receive more favorable treatment when calculating adjusted financial statement income, addressing an issue that regulated utilities had raised under earlier CAMT rules.

Exelon continues to lobby on H.R. 2872 and CAMT policy even after receiving relief through administrative guidance, keeping Congress involved in the debate over whether the treatment of utility repair and maintenance expenses should also be addressed through legislation.

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