Income Taxes

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



	Years Ended December 31,
	2016		2015		2014
Domestic	$	349,041	$	461,293	$	341,070
Foreign^(a)	24,813		12,536		(6,000		)
	$	373,854	$	473,829	$	335,070


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

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



	Years Ended December 31,
	2016			2015			2014
Current:
Federal	$	(227	)	$	495		$	213
Foreign	(6,820		)	(5,675		)	(6,413		)
State	(1,231		)	(3,981		)	(4,415		)
Total current	(8,278		)	(9,161		)	(10,615		)
Deferred:
Federal	(7,968		)	44,716			23,070
Foreign	(601		)	(1,048		)	(819		)
State	(34		)	16,950			(392		)
Total deferred	(8,603		)	60,618			21,859
Total tax benefit (provision)	$	(16,881	)	$	51,457		$	11,244

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



	Years Ended December 31,
	2016			2015			2014
Benefit (provision) for income taxes at statutory rate	$	(130,849	)	$	(165,840	)	$	(117,274	)
Tax effect of foreign income (losses)	1,215			(527		)	(4,296		)
Tax adjustment related to REIT operations	121,092			186,649			132,951
Tax adjustment related to the inclusion of small cells in the REIT^(a)	—			33,759			—
Expenses for which no federal tax benefit was recognized	(43		)	(414		)	(463		)
Valuation allowances	(21		)	3,000			9,000
State tax (provision) benefit, net of federal	(1,085		)	1,210			(3,136		)
Foreign tax	(7,421		)	(6,723		)	(7,232		)
Other	231			343			1,694
	$	(16,881	)	$	51,457		$	11,244


(a)	During the fourth quarter of 2015, the Company de-recognized the net deferred tax liabilities related to the Company's small cells previously included in one or more TRSs in conjunction with the inclusion of small cells in the REIT in January 2016.

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



	December 31,
	2016			2015
Deferred income tax liabilities:
Property and equipment	$	3,945		$	334
Deferred site rental receivable	6,192			5,742
Intangible assets	—			—
Total deferred income tax liabilities	10,137			6,076
Deferred income tax assets:
Intangible assets	22,377			40,654
Net operating loss carryforwards	21,143			7,891
Deferred ground lease payable	1,646			1,312
Accrued liabilities	5,511			4,183
Receivables allowance	383			196
Other	1,726			1,252
Valuation allowances	(6,627		)	(1,994		)
Total deferred income tax assets, net	46,159			53,494
Net deferred income tax asset (liabilities)	$	36,022		$	47,418

The Company operates as a REIT for U.S. federal income tax purposes. During the fourth quarter of 2015, the Company completed the necessary steps to include its small cells that were previously included in one or more TRSs in the REIT. As a result, during the fourth quarter of 2015, the Company de-recognized the net deferred tax liabilities in conjunction with the inclusion of small cells in the REIT, which resulted in a net non-cash income tax benefit of $33.8 million. Effective January 4, 2016, the Company's small cells that were previously included in one or more TRSs are included in the REIT.

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



	December 31, 2016									December 31, 2015
Classification	Gross			Valuation Allowance			Net			Gross			Valuation Allowance			Net
Federal	$	42,948		$	(21	)	$	42,927		$	48,273		$	—		$	48,273
State	1,170			—			1,170			1,203			—			1,203
Foreign	(1,469		)	(6,606		)	(8,075		)	(64		)	(1,994		)	(2,058		)
Total	$	42,649		$	(6,627	)	$	36,022		$	49,412		$	(1,994	)	$	47,418

At December 31, 2016, the Company had U.S. federal and state NOLs of approximately $1.3 billion and $0.6 billion, respectively, which are available to offset future taxable income. These amounts include approximately $237 million of losses related to stock-based compensation. The Company also has foreign NOLs of $54.1 million. If not utilized, the Company's U.S. federal NOLs expire starting in 2024 and ending in 2036, the state NOLs expire starting in 2017 and ending in 2036, and the foreign NOLs expire starting in 2017 and ending in 2024. 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 certain foreign net deferred tax assets (primarily NOLs).

As of December 31, 2016, the total amount of unrecognized tax benefits that would impact the effective tax rate, if recognized, was $3.1 million. The aggregate changes in the balance of unrecognized tax benefits are as follows:



	Years Ended December 31,
	2016			2015
Balance at beginning of year	$	6,770		$	8,333
Additions based on prior year tax positions	116			212
Reductions as a result of the lapse of statute limitations	(3,806		)	(1,775		)
Balance at end of year	$	3,080		$	6,770

From time to time, the Company is subject to examinations by various tax authorities in jurisdictions in which the Company has business operations. At this time, the Company is not subject to an IRS examination. The Australian Taxation Office is conducting an audit of the tax consequences for Australian tax purposes of the Company’s sale of CCAL. The Company regularly assesses the likelihood of additional assessments in each of the tax jurisdictions. The Company believes it has adequately provided for uncertain tax positions and does not believe assessments, if any, arising from current or future examination or audits will have a material effect on the Company's financial statements.

As of December 31, 2016, the Company's deferred tax assets are included in "long-term prepaid rent and other assets, net" and the Company's deferred tax liabilities are included in "other long-term liabilities" on the Company's consolidated balance sheet. See note 2 for a discussion of recently adopted guidance on the presentation of deferred tax assets and deferred tax liabilities.