Brown & Williamson Tobacco

Form 990, Schedule D, Part X, Ln 2

“ASC 740 DISCLOSURE The VEBA trusts funding certain benefits of the Plan received exemption letters from the Internal Revenue Service (IRS) for the Non-Collectively Bargained Trust and the Collectively Bargained Trust dated January 9, 1979 and January 18, 1994, respectively, stating that the trusts are tax-exempt under the provisions of Section 501(c)(9) of the Internal Revenue Code (the IRC). However, as a result of the Plan's funding policy, from time to time the trust may be subject to income taxes. No federal or state income taxes have been recorded in 2024 for unrelated business taxable income. In addition, the Plan and the trust are required to operate in conformity with the IRC to maintain the tax-exempt status of the trust. The plan administrator believes that the Plan is being operated in compliance with the applicable requirements of the IRC and, therefore, believes that the related trust is tax-exempt. U.S. generally accepted accounting principles require plan management to evaluate tax positions taken by the Plan and recognize a tax liability (or asset) if the Plan has taken an uncertain position that more likely than not would not be sustained upon examination by the Internal Revenue Service. Plan management has analyzed the tax positions taken by the Plan, and has concluded that as of December 31, 2024, there are no uncertain positions taken or expected to be taken that would require recognition of a liability (or asset) or disclosure in the financial statements. The Plan is subject to routine audits by taxing jurisdictions; however, there are currently no audits for any tax periods in progress.”