Income Taxes

The components of the provision (benefit) for income taxes for each of the three years in the period ended December 31, 2014 are as follows:



	Year ended December 31,
	2014		2013		2012
Current
Federal	$	2	$	10	$	—
Foreign	42		39		27
State and local	5		2		2
	49		51		29
Deferred
Federal	240		149		(22		)
Foreign	2		4		2
State and local	19		14		4
	261		167		(16		)
Total	$	310	$	218	$	13

A reconciliation of the provision for income taxes and the amount computed by applying the statutory federal income tax rate of 35 percent to the income before provision for income taxes for each of the three years in the period ended December 31, 2014 is as follows:



	Year ended December 31,
	2014			2013			2012
Computed tax at statutory tax rate	$	297		$	212		$	31
State income taxes, net of federal tax benefit (1)	22			15			5
Non-deductible expenses and other (2)	8			8			(8		)
Foreign taxes	(17		)	(17		)	(15		)
Total	$	310		$	218		$	13


(1)	2012 state income taxes, net of federal tax benefit includes $8 of expense primarily related to the write-off of certain state deferred tax assets as a result of the RSC acquisition.

(2) 2012 non-deductible expenses and other includes a $6 Canadian tax benefit due to settlements with the Canadian Revenue Authority and a $2 transfer pricing tax benefit.

The components of deferred income tax assets (liabilities) are as follows:



	December 31, 2014								December 31, 2013
	Current		Non Current			Total			Current		Non Current			Total
Reserves and allowances	$	66	$	41		$	107		$	54	$	59		$	113
Intangibles	1		—			1			—		—			—
Debt cancellation and other	—		58			58			—		41			41
Net operating loss and credit carryforwards	181		56			237			206		69			275
Total deferred tax assets	248		155			403			260		169			429
Property and equipment	—		(1,535		)	(1,535		)	—		(1,259		)	(1,259		)
Intangibles	—		(312		)	(312		)	—		(369		)	(369		)
Valuation allowance	—		—			—			—		—			—
Total deferred tax liability	—		(1,847		)	(1,847		)	—		(1,628		)	(1,628		)
Total deferred income tax asset (liability)	$	248	$	(1,692	)	$	(1,444	)	$	260	$	(1,459	)	$	(1,199	)

The following table summarizes the activity related to unrecognized tax benefits, all of which would impact our effective tax rate if recognized:



	2014		2013
Balance at January 1	$	7	$	5
Additions for tax positions of prior years	—		2
Balance at December 31	$	7	$	7

We include interest accrued on the underpayment of income taxes in interest expense, and penalties, if any, related to unrecognized tax benefits in selling, general and administrative expense. Interest expense of less than $1 related to income tax was reflected in our consolidated statements of income for each of the years ended December 31, 2014, 2013 and 2012.

We file income tax returns in the United States and in several foreign jurisdictions. With few exceptions, we have completed our domestic and international income tax examinations, or the statute of limitations has expired in the respective jurisdictions, for years prior to 2007. The Internal Revenue Service (“IRS”) has completed audits for periods prior to 2010. Canadian authorities have concluded income tax audits for periods through 2010. Canadian authorities have issued reassessments associated with completed Canadian transfer pricing audits for 2006 through 2010. Included in the balance of unrecognized tax benefits at December 31, 2014 are certain tax positions associated with Canadian transfer pricing. The Company has submitted a request to Canadian Competent Authority for resolution and is filing for an Advanced Pricing Arrangement ("APA") associated with our intercompany transactions. It is reasonably possible that the Canadian Competent Authority or APA request will be concluded within the next 12 months, and that the conclusion of either request will result in a settlement of reported unrecognized tax benefits for those tax positions during the next 12 months. However, based on the status of the ongoing requests and alternative settlement options available to the Company for certain of these tax positions, which could include legal proceedings, it is not possible to estimate the amount of the change, if any, to the previously recorded uncertain tax positions.

For financial reporting purposes, income before provision for income taxes for our foreign subsidiaries was $168, $153 and $144 for the years ended December 31, 2014, 2013 and 2012, respectively. At December 31, 2014, unremitted earnings of foreign subsidiaries were approximately $595. Since it is our intention to indefinitely reinvest these earnings, no U.S. taxes have been provided for these amounts. If we changed our reinvestment policy and decided to remit earnings as a dividend, a deferred tax liability would arise. Determination of the amount of unrecognized deferred tax liability on these unremitted taxes is not practicable.

We have net operating loss carryforwards (“NOLs”) of $915 for state income tax purposes that expire from 2015 through 2034. We have recorded a valuation allowance against this deferred asset of less than $1 as of December 31, 2014 and 2013. We have NOLs of $463 for federal income tax purposes that expire beginning in 2032. We have a federal alternative minimum tax (“AMT”) credit carryforward of $29. We have not recorded a valuation allowance against these deferred tax assets because it is deemed more likely than not that such benefits will be realized in the future. There were no new NOLs for federal income tax recognized in 2014. In 2014, the Company utilized $71 of existing NOLs to offset tax liabilities.