Income Taxes

Income (loss) before income taxes by geographic area is as follows:



	Years Ended December 31,
	2014		2013		2012
Domestic	$	341,070	$	260,364	$	77,254
Foreign^(a)	47,064		32,165		23,573
	$	388,134	$	292,529	$	100,827


(a)	Inclusive of income (loss) before income taxes from Australia and Puerto Rico.

The benefit (provision) for income taxes consists of the following:



	Years Ended December 31,
	2014			2013			2012
Current:
Federal	$	213		$	684		$	229
Foreign	(10,737		)	(6,732		)	(6,837		)
State	(4,415		)	(12,305		)	(3,705		)
Total current	(14,939		)	(18,353		)	(10,313		)
Deferred:
Federal	23,070			(164,769		)	65,643
Foreign	2,901			(6,136		)	42,714
State	(392		)	(9,370		)	2,017
Total deferred	25,579			(180,275		)	110,374
Total tax benefit (provision)	$	10,640		$	(198,628	)	$	100,061

A reconciliation between the benefit (provision) for income taxes and the amount computed by applying the federal statutory income tax rate to the loss before income taxes is as follows:



	Years Ended December 31,
	2014			2013			2012
Benefit (provision) for income taxes at statutory rate	$	(135,847	)	$	(102,385	)	$	(35,289	)
Tax effect of foreign income (losses)	14,277			11,258			8,251
Tax adjustment related to REIT operations	132,951			—			—
Tax adjustment related to the REIT election^(a)	—			(67,395		)	—
Expenses for which no federal tax benefit was recognized	(463		)	(9,570		)	(3,874		)
Valuation allowances	9,000			—			95,072
State tax (provision) benefit, net of federal	(3,136		)	(14,852		)	(1,097		)
Foreign tax	(7,836		)	(12,868		)	35,877
Other	1,694			(2,816		)	1,121
	$	10,640		$	(198,628	)	$	100,061


(a)	Inclusive of a $39.8 million adjustment during the year ended December 31, 2013 to reclassify a deferred tax charge from AOCI to the provision for income taxes.

The components of the net deferred income tax assets and liabilities are as follows:



	December 31,
	2014			2013
Deferred income tax liabilities:
Property and equipment	$	144,020		$	135,824
Deferred site rental receivable	35,887			28,074
Intangible assets	108,689			116,548
Total deferred income tax liabilities	288,596			280,446
Deferred income tax assets:
Net operating loss carryforwards	148,465			134,123
Deferred ground lease payable	7,231			7,122
Accrued liabilities	162,108			148,580
Receivables allowance	1,538			1,228
Other	1,278			5,866
Valuation allowances	(21,038		)	(27,264		)
Total deferred income tax assets, net	299,582			269,655
Net deferred income tax asset (liabilities)	$	10,986		$	(10,791	)

During 2014, the Company reversed $9.0 million of valuation allowance associated with federal NOLs of its TRSs as the Company has determined that these NOLs will be realized.

During the fourth quarter of 2013, the Company completed the steps necessary to qualify to operate as a REIT for U.S. federal income tax purposes and received final approval from the Company's board of directors. As a result, the Company de-recognized the net deferred tax assets and liabilities related to the entities included in the REIT, which resulted in net non-cash income tax charge of $67.4 million in conjunction with the anticipated REIT conversion. Included in the REIT conversion charge of $67.4 million is a $39.8 million adjustment to reclassify a deferred tax charge from AOCI to the provision for income taxes.

During 2013, in connection with completing the steps necessary to qualify to operate as a REIT, the Company reversed $29.4 million of valuation allowance associated with capital loss carryforwards as the Company generated sufficient capital gains in 2013 to fully realize these capital loss carryforwards. Also, during 2013, the Company recorded a valuation allowance of $12.0 million against federal NOLs of its TRSs as the Company determined that a portion of its TRSs federal NOLs more likely than not will not be realized.

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



	December 31, 2014								December 31, 2013
Classification	Gross		Valuation Allowance			Net			Gross			Valuation Allowance			Net
Federal	$	6,557	$	(3,000	)	$	3,557		$	(7,513	)	$	(12,000	)	$	(19,513	)
State	462		(16,208		)	(15,746		)	(807		)	(14,547		)	(15,354		)
Foreign	25,005		(1,830		)	23,175			24,793			(717		)	24,076
Total	$	32,024	$	(21,038	)	$	10,986		$	16,473		$	(27,264	)	$	(10,791	)

At December 31, 2014, the Company had U.S. federal and state NOLs of approximately $2.2 billion and $0.9 billion, respectively, which are available to offset future taxable income. These amounts include $0.2 billion of losses related to stock-based compensation. The Company also had foreign NOLs of $70.0 million. If not utilized, the Company's U.S. federal NOLs expire starting in 2022 and ending in 2032, and the state NOLs expire starting in 2015 and ending in 2034. The foreign NOLs predominately remain available indefinitely provided certain continuity of business requirements are met. The utilization of the NOLs is subject to certain limitations. The Company's U.S. federal and state income tax returns generally remain open to examination by taxing authorities until three years after the applicable NOLs have been used or expired. The remaining valuation allowance relates to federal NOLs and certain state net deferred tax assets (primarily NOLs).

As of December 31, 2014, the total amount of unrecognized tax benefits that would impact the effective tax rate, if recognized, was $8.3 million. The aggregate changes in the balance of unrecognized tax benefits are as follows:



	Years Ended December 31,
	2014			2013
Balance at beginning of year	$	21,549		$	19,184
Additions based on current year tax positions	286			2,365
Reductions as a result of the lapse of statute limitations	(6,042		)	—
Reductions as a result of settlements with taxing authorities	(7,460		)	—
Balance at end of year	$	8,333		$	21,549

From time to time, the Company is subject to examinations by various tax authorities in jurisdictions in which the Company has business operations. The Company regularly assesses the likelihood of additional assessments in each of the tax jurisdictions resulting from these examinations. At this time, the Company is not subject to an IRS examination.