The Company's pre-tax income from continuing operations before equity in earnings of equity method investees consisted of approximately $1.1 billion, $0.9 billion and $1.0 billion from U.S. operations and pre-tax income (loss) of $15 million, $(1) million and $(7) million from foreign operations for the years ended December 31, 2019, 2018 and 2017, respectively.

The Company recognized the income tax effects of the Tax Cut and Jobs Act ("TCJA") in its 2017 consolidated financial statements in accordance with Staff Accounting Bulletin No. 118, which provides Securities and Exchange Commission staff guidance for the application of Accounting Standards Codification Topic 740, Income Taxes, in the reporting period in which the TCJA was signed into law. As such, the Company’s 2017 financial results reflected the provisional estimate of the income tax effects of the TCJA.

During the year ended December 31, 2017, the Company recorded a provisional estimated income tax benefit of $106 million associated with the TCJA, including a deferred income tax benefit of $115 million primarily due to the remeasurement of net deferred tax liabilities and reserves at the new combined federal and state tax rate, partially offset by $9 million of current tax expense primarily due to the mandatory repatriation toll charge on undistributed foreign earnings and profits. The Company did not identify items for which the income tax effects of the TCJA had not been completed and a reasonable estimate could not be determined as of December 31, 2017. During the year ended December 31, 2018, the Company finalized the effect of the enactment of TCJA and recorded an additional $1 million of current income tax expense.

As a result of the TCJA, the Company changed its assertion that it intends to indefinitely reinvest undistributed earnings from certain non-U.S. subsidiaries outside the U.S. The Company is indefinitely reinvested in the remaining basis difference and it is not practicable to determine the associated amount of unrecognized deferred tax liability.



	2019			2018			2017
Current:
Federal	$	176		$	82		$	226
State and local	53			26			5
Foreign	3			1			1
Deferred:
Federal	21			66			(20		)
State and local	(4		)	10			27
Foreign	(2		)	(3		)	2
Total	$	247		$	182		$	241



	2019		2018		2017

Tax provision at statutory rate	21.0	%	21.0	%	35.0	%
State and local income taxes, net of federal benefit	4.6		4.7		3.8
Gains and losses on book and tax basis difference	—		—		(0.1	)
Impact of noncontrolling interests	(1.1	)	(1.4	)	(1.9	)
Excess tax benefits on stock-based compensation arrangements	(1.2	)	(1.9	)	(3.6	)
Return to provision true-ups	(1.4	)	(1.4	)	(2.0	)
Impact of TCJA enactment	—		0.1		(10.4	)
Change in accounting method	—		(1.6	)	—
Impact of equity earnings	1.1		1.0		1.1
Changes in reserves for uncertain tax positions	1.7		(0.8	)	1.6
Change in valuation allowances associated with certain net operating losses	(1.1	)	—		0.4
Other, net	(0.6	)	—		(0.5	)
Effective tax rate	23.0	%	19.7	%	23.4	%

For the year ended December 31, 2019, the Company recognized a $12 million net income tax benefit due to the release of valuation allowances associated with certain net operating loss carryforwards. In 2018, the Company filed for a tax return accounting method change, effective for the tax year ending December 31, 2017, to accelerate the deduction of certain expenses on its 2017 tax return at the higher 2017 federal corporate statutory income rate, resulting in a $15 million income tax benefit. The net income tax benefit associated with changes in reserves for uncertain tax positions in 2018 was primarily related to the expiration of the statute of limitations for certain income tax returns.



	2019			2018
Non-current deferred tax assets (liabilities):
Accounts receivable reserves	$	64		$	66
Liabilities not currently deductible	126			137
Stock-based compensation	35			38
Basis differences in investments, joint ventures and subsidiaries	(80		)	(80		)
Net operating loss carryforwards, net of valuation allowance	75			80
Depreciation and amortization	(484		)	(484		)
Total non-current deferred tax liabilities, net	$	(264	)	$	(243	)

As of December 31, 2019, the Company had estimated net operating loss carryforwards for federal and state income tax purposes of $92 million and $1.1 billion, respectively, which expire at various dates through 2039. Estimated net operating loss carryforwards for foreign income tax purposes are $49 million as of December 31, 2019, some of which can be carried forward indefinitely while others expire at various dates through 2039. As of December 31, 2019 and 2018, deferred tax assets associated with net operating loss carryforwards of $101 million and $126 million, respectively, have each been reduced by valuation allowances of $26 million and $46 million, respectively.

Income taxes payable, including those classified as long-term in other liabilities as of December 31, 2019 and 2018, were $113 million and $85 million, respectively. Prepaid income taxes were $3 million and $14 million as of December 31, 2019 and 2018, respectively, and were recorded in prepaid expenses and other current assets.



	2019			2018			2017

Balance, beginning of year	$	107		$	115		$	98
Additions:
For tax positions of current year	2			2			5
For tax positions of prior years	16			11			23
Reductions:
Changes in judgment	(3		)	(6		)	(2		)
Expirations of statutes of limitations	(2		)	(15		)	(6		)
Settlements	(32		)	—			(3		)
Balance, end of year	$	88		$	107		$	115

The contingent liabilities for tax positions primarily relate to uncertainties associated with the realization of tax benefits derived from the allocation of income and expense among state jurisdictions, the characterization and timing of certain tax deductions associated with business combinations, income and expenses associated with certain intercompany licensing arrangements, certain tax credits and the deductibility of certain settlement payments.

The total amount of unrecognized tax benefits as of December 31, 2019, that, if recognized, would affect the effective income tax rate is $72 million. Based upon the expiration of statutes of limitations, settlements and/or the conclusion of tax examinations, the Company believes it is reasonably possible that the total amount of unrecognized tax benefits may decrease by up to $10 million within the next twelve months.

Accruals for interest expense on contingent tax liabilities are classified in income tax expense in the consolidated statements of operations. Accruals for penalties have historically been immaterial. Interest expense included in income tax expense in each of the years ended December 31, 2019, 2018 and 2017 was approximately $5 million, $1 million and $1 million, respectively. As of December 31, 2019 and 2018, the Company has approximately $17 million and $14 million, respectively, accrued, net of the benefit of a federal and state deduction, for the payment of interest on uncertain tax positions.

The recognition and measurement of certain tax benefits includes estimates and judgment by management and inherently involves subjectivity. Changes in estimates may create volatility in the Company's effective tax rate in future periods and may be due to settlements with various tax authorities (either favorable or unfavorable), the expiration of the statute of limitations on some tax positions and obtaining new information about particular tax positions that may cause management to change its estimates.

In the regular course of business, various federal, state, local and foreign tax authorities conduct examinations of the Company's income tax filings and the Company generally remains subject to examination until the statute of limitations expires for the respective jurisdiction. The Internal Revenue Service has either completed its examinations of the Company's consolidated federal income tax returns or the statute of limitations has expired up through and including the 2014 tax year. At this time, the Company does not believe that there will be any material additional payments beyond its recorded contingent liability reserves that may be required as a result of these tax audits. As of December 31, 2019, a summary of the tax years that remain subject to examination, awaiting approval, are under appeal, or are otherwise unresolved for the Company's major jurisdictions are: