Micron earned $99.67 billion before income taxes in its fiscal 2026, and $94.85 billion of it, 95.2%, was booked outside the United States, according to the tax note in its annual report. Its net US federal income tax provision for the year came to $260 million, by our arithmetic from the filing.
Economist Brad Setser pointed to the figures on X on 6 November, writing that Micron “looks to have set aside $260m to pay US federal corporate income tax, and over $14b to pay income ta abroad — primarily in Singapore”.
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The key insight: As we read Micron’s 10-K, the memory boom’s profit sat mostly outside the US: $94.85 billion of its $99.67 billion fiscal 2026 pre-tax income was booked abroad, and its foreign tax provision came to about 15.0% of foreign pre-tax income, the level of the Pillar Two minimum, by our arithmetic, while its net US federal provision was $260 million.
Micron’s fiscal year ended “September 3, 2026”. Revenue was $133.19 billion, and the filing says total revenue “increased 256% as compared to 2025 primarily due to increases in sales of both DRAM and NAND products”.
Note 18 splits income before income taxes into $4.82 billion in the US and $94.85 billion abroad. The current US federal provision was $782 million and the deferred US federal line was a $522 million benefit, which nets to $260 million. The current foreign provision was $14.18 billion.
The total income tax provision was $14.76 billion, an effective rate of 14.8%, up from 11.6% in fiscal 2025. Cash paid for income taxes, net of refunds, was $1.25 billion: $275 million federal, $153 million state, $481 million in Singapore and $345 million in other jurisdictions.
Micron fiscal 2026 income before income taxes by location and tax lines, from Note 18 of its 10-K: $94.85 billion foreign and $4.82 billion US pre-tax income; a $14.18 billion current foreign provision; a $260 million net US federal provision ($782 million current less a $522 million deferred benefit, our arithmetic).
Why the Rate Is Where It Is
The filing’s rate reconciliation starts at the 21% US statutory rate and subtracts 6.0 points for the “Singapore Tax rate differential”. Micron says the rise in its rate from 2025 “was primarily due to the 15% minimum tax Pillar Two Model Rules”, and that “Singapore enacted legislation to implement Pillar Two, effective for us in 2026, which largely offsets the benefit from our Singapore tax incentive arrangements”.
The 10-K says “tax incentive arrangements in Singapore reduced our income tax provision by $ 11.22 billion”, and that “This benefit was largely offset by $ 9.03 billion of qualified domestic minimum top-up taxes resulting from Singapore’s implementation of the OECD Pillar Two framework”. The net benefit was $2.21 billion. The incentives “expire, in whole or in part, at various dates through 2034”.
On its foreign income, Micron’s foreign tax provision, current plus deferred, was $14.28 billion, about 15.0% of its $94.85 billion of foreign pre-tax income, by our arithmetic. That is the level of the Pillar Two minimum.
Our Number
The $260 million net US federal provision equals 0.26% of Micron’s total pre-tax income and 5.4% of the $4.82 billion it booked in the US, by our arithmetic. The current US federal provision alone, $782 million, is 16.2% of US pre-tax income. The current foreign provision of $14.18 billion is about 55 times the net US federal figure.
Setser wrote in a follow-up post that “there is a huge gap between Micron’s effective tax rate in the US and its global effective tax rate”. The filing itself does not compare the two.
As we read Note 18, the $260 million is a net figure: a $782 million current US federal provision less a $522 million deferred benefit, by our arithmetic.
As we read the rate discussion, Micron attributes the rise in its effective rate from 11.6% to 14.8% primarily to Pillar Two, which it says largely offsets its Singapore incentives: $11.22 billion of incentive benefit against $9.03 billion of top-up taxes.
As we read the cash-flow disclosure, cash paid for income taxes was $1.25 billion, of which $275 million was federal; the provision of $14.76 billion and cash paid are different measures.
Micron Technology 10-K, fiscal 2026
“Singapore enacted legislation to implement Pillar Two, effective for us in 2026, which largely offsets the benefit from our Singapore tax incentive arrangements.”
Three Implications
FOR INVESTORS Micron reported an effective tax rate of 14.8%, against 11.6% the year before, per the 10-K.
FOR TAX POLICY The 10-K says the Singapore incentives expire, in whole or in part, at various dates through 2034.
FOR READERS How intercompany pricing splits profit between the US and Singapore is not established in the filing.
The analysis says: “Memory is becoming the new compute.”
As we read it, Micron’s 10-K shows where that memory boom’s profit was booked. The analysis does not discuss Micron’s taxes.
What Is Not Established
The filing does not say how much of the US deferred benefit will reverse in later years, how intercompany pricing splits profit between the US and Singapore, or what Micron will owe once the Singapore incentives expire. We did not contact Micron or Setser.
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Micron booked $94.85 billion of its $99.67 billion fiscal 2026 pre-tax income outside the US and recorded a $14.18 billion current foreign tax provision, which Setser described as primarily in Singapore. Its net US federal provision was $260 million, 0.26% of pre-tax income, by our arithmetic; its global effective rate was 14.8%.
A note on sourcing. Every figure is from Micron’s 10-K for fiscal 2026 (Note 18, Income Taxes, and the results of operations). The net US federal figure and the percentages are our arithmetic. Brad Setser’s posts are quoted as the lead. We did not contact Micron or Setser.
Gennaro Cuofano is a CRO and tech executive who has worked in AI since late 2015, starting with bringing NLP, natural-language generation, voice and chatbot products to the marketing industry. His background is in law and finance: he holds a Master's degree in Law and an International MBA with an emphasis on corporate finance (LUISS Business School and the University of San Diego, 2012), and worked as a financial analyst at a real-estate investment firm in San Diego and as an assistant controller. His work focuses on business model strategy, business engineering and, more broadly, structural analysis: how companies make money, read from their own filings. He created FourWeekMBA and leads research there and at The Business Engineer, his newsletter on AI and business strategy, with over 95,000 subscribers and more than 1,000 published analyses. His writing has also appeared on Entrepreneur (for example, How to Digitize a Family Business in Europe) and HackerNoon. Find him on LinkedIn and Substack. See how we source.
