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Income Taxes
12 Months Ended
Dec. 31, 2020
Income Tax Disclosure [Abstract]  
Income Taxes Income Taxes
The components of the provision (benefit) for income taxes for each of the three years in the period ended December 31, 2020 are as follows:
Year ended December 31,
202020192018
Current
Federal$290 $97 $47 
Foreign15 (6)18 
State and local654558 
370136123 
Deferred
Federal(107)185 243 
Foreign14 
State and local(20)11 
(121)204 257 
Total$249 $340 $380 

A reconciliation of the provision (benefit) for income taxes and the amount computed by applying the statutory federal income tax rate of 21 percent to the income before provision (benefit) for income taxes for each of the three years in the period ended December 31, 2020 is as follows:
Year ended December 31,
202020192018
Computed tax at statutory tax rate$239 $318 $310 
State income taxes, net of federal tax benefit31 43 54 
Other permanent items(3)(17)(1)
Change in valuation allowance(22)(3)
Enactment of the Tax Act (1)— — 
Foreign tax rate differential(1)
Total$249 $340 $380 
 
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(1)    The Tax Act was enacted in December 2017 and required (i) the revaluation of our net deferred tax liability based on a U.S. federal tax rate of 21 percent and (ii) a one-time transition tax for deemed repatriation of accumulated undistributed earnings of certain foreign investments. We primarily recognized the accounting for the enactment of the Tax Act upon adoption in 2017, and finalized the accounting in 2018.
The components of deferred income tax assets (liabilities) are as follows:
December 31, 2020December 31, 2019
Reserves and allowances$129 $111 
Debt cancellation and other10 
Net operating loss and credit carryforwards242371
Operating lease assets183182
Total deferred tax assets564672
Less: valuation allowance (1)(21)(43)
Total net deferred tax assets543629
Property and equipment, including rental equipment(1,962)(2,135)
Operating lease liabilities(183)(182)
Intangibles(166)(199)
Total deferred tax liability(2,311)(2,516)
Total net deferred tax liability$(1,768)$(1,887)
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(1)    Relates to foreign tax credits, state net operating loss carryforwards, and state tax credits that may not be realized. All of the remaining valuation allowance for foreign tax credits was released in 2020.
We file income tax returns in the U.S., Canada and Europe. Without exception, 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 2011.
For financial reporting purposes, income before provision for income taxes for our foreign subsidiaries was $83, $62 and $71 for the years ended December 31, 2020, 2019 and 2018, respectively.
We have historically considered the undistributed earnings of our foreign subsidiaries to be indefinitely reinvested, and, accordingly, no taxes were provided on such earnings prior to the fourth quarter of 2020. In the fourth quarter of 2020, we identified $135 of cash in our foreign operations in excess of near-term working capital needs, and determined that this amount could no longer be considered indefinitely reinvested. As a result, our prior assertion that all undistributed earnings of our foreign subsidiaries should be considered indefinitely reinvested has changed, and, in the fourth quarter of 2020, we recorded the immaterial taxes on a distribution of the $135 of cash.
We continue to expect that the remaining balance of our undistributed foreign earnings will be indefinitely reinvested. If we determine that all or a portion of such foreign earnings are no longer indefinitely reinvested, we may be subject to additional foreign withholding taxes and U.S. state income taxes. At December 31, 2020, unremitted earnings of foreign subsidiaries were $840. Determination of the amount of unrecognized deferred tax liability on these unremitted earnings is not practicable.
We have net operating loss carryforwards (“NOLs”) of $759 for federal income tax purposes that expire from 2030 through 2037, $3 for foreign income tax purposes that expire from 2024 through 2029 and $744 for state income tax purposes that expire from 2021 through 2034.