Citigroup, Abbott Laboratories, and AT&T
are among the 26 companies that paid more to their CEOs in 2011
than they did in U.S. federal taxes, according to a study
released on Thursday.

Tax breaks on research and development, past losses, and
foreign-held earnings were among those lightening the tax load
for many companies on the list, said the Institute for Policy
Studies, a left-leaning think tank in Washington, D.C.

Citi, Abbott and AT&T all took issue with the institute's
methodology. All three said they paid all taxes owed in 2011.

During a presidential election cycle in which wealth and
taxes are often debated, the study's authors said the U.S. tax
code has become an enabler of large CEO pay, while also offering
companies ways to reduce their tax bills.

Four pay-related tax breaks combined to cost taxpayers $14
billion in uncollected federal taxes, the report said.

The four included breaks dealing with performance-based
chief executive pay and stock options, as well as the
preferential 15 percent tax rate on carried interest enjoyed by
private equity partners and other financiers, it said.

Compensation for the 26 CEOs whose pay surpassed their
companies' corporate tax bills averaged $20.4 million, according
to the study. That average was up 23 percent over last year.

The average was also significantly higher than pay tracked
by separate studies of broader groups. For instance, $10.3
million was the average 2011 direct compensation for 300
large-company CEOs tracked by pay consultants Hay Group.


To get its list, the institute compared CEO pay to current
U.S. taxes paid, excluding foreign and state and local taxes
that may also have been paid, as well as deferred taxes that can
often be far larger than current taxes paid.

The group's rationale was that U.S. taxes paid are the
closest approximation available in public documents to what
companies may have actually written in their checks for last
year to the U.S. Internal Revenue Service.

Among companies topping the institute's list:

* Citigroup, the financial services giant, with a tax
refund of $144 million based on prior losses, paid CEO Vikram
Pandit $14.9 million in 2011, despite an advisory vote against
it by 55 percent of shareholders.

* Telecoms group AT&T paid CEO Randall Stephenson
$18.7 million, but was entitled to a $420 million tax refund
thanks to billions in tax savings from recent rules accelerating
depreciation of assets.

* Drugmaker Abbott Laboratories paid CEO Miles White
$19 million, while garnering a $586 million refund. Abbott has
64 subsidiaries in 16 countries considered by authorities to be
tax havens, the institute said.


"This is a blatant misrepresentation of the facts," Abbott
spokesman Scott Stoffel said.

He said Abbott did not get a rebate, but paid the U.S.
government $700 million in federal income taxes in 2011, and
that the report's numbers reflect a non-cash accounting
adjustment caused by the resolution of various tax matters.

A Citigroup spokeswoman said that, while the company did not
pay federal income tax in 2011, that was due to substantial
losses it recorded in 2008 and 2009, a break available to all
businesses in similar straits.

She also noted that Citi paid on average $3.7 billion a year
in federal income taxes from 2000 to 2006, and paid other taxes
last year, including more than $3 billion in payroll taxes, and
that Pandit voluntarily took a salary of just $1 in 2010.

AT&T said in a statement its CEO's pay was closely tied to
performance and was fair, and that the accelerated deductions
that lowered its federal taxes stemmed in part from $20 billion
spent in support of the U.S. economy and jobs. The company
reported paying $3.8 billion in other taxes last year, and
hundreds of millions in federal income taxes in 2010.

All the tax breaks identified in the study are legal and
shareholders generally expect companies to take advantage of any
reasonable tax breaks they can, said David Wise, a senior
principal with Hay Group.

If the tax code changed to eliminate pay-related deductions,
like the stock option deduction, he said, "individual companies
could navigate that fairly easily. But collectively, those
dollars would add up and increase the tax base."