Income Taxes

12 Months Ended

Dec. 31, 2022

Income Tax Disclosure [Abstract]

Income Taxes

Income Taxes

Income (loss) from continuing operations before income taxes by geographic area is summarized in the table below.

	Years Ended December 31,
	2022		2021		2020
Domestic	$	1,661	$	1,144	$	1,046
Foreign(a)	30		35		30
Total	$	1,691	$	1,179	$	1,076

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

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

	Years Ended December 31,
	2022		2021		2020
Current:
Federal	$	(6)	$	(5)	$	(6)
Foreign	(9)		(8)		(6)
State	2		(4)		(5)
Total current	(13)		(17)		(17)
Deferred:
Foreign	(3)		(4)		(3)
Total deferred	(3)		(4)		(3)
Total tax benefit (provision)	$	(16)	$	(21)	$	(20)

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) from continuing operations before income taxes is as follows:

	Years Ended December 31,
	2022		2021		2020
Benefit (provision) for income taxes at statutory rate	$	(355)	$	(248)	$	(225)
Tax adjustment related to REIT operations	349		243		219
Valuation allowances	(1)		—		—
State tax (provision) benefit, net of federal	2		(4)		(5)
Foreign tax	(11)		(12)		(9)
Total	$	(16)	$	(21)	$	(20)

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

	December 31,
	2022		2021
Deferred income tax liabilities:
Property and equipment	$	8	$	7
Deferred site rental receivables	9		8
Total deferred income tax liabilities	17		15
Deferred income tax assets:
Intangible assets	1		1
Net operating loss carryforwards(a)	12		13
Straight-line rent expense liability	4		4
Accrued liabilities	6		6
Other	4		2
Valuation allowances	(2)		—
Total deferred income tax assets, net	25		26
Net deferred income tax assets (liabilities)	$	8	$	11

(a)Balance results from the Company's foreign NOLs. Due to the Company's REIT status, no federal or state NOLs result in the Company recording a deferred income tax asset. See further discussion surrounding the Company's NOL balances below.

The Company operates as a REIT for U.S. federal income tax purposes.

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

	December 31, 2022						December 31, 2021
Classification	Gross		Valuation Allowance		Net		Gross		Valuation Allowance		Net
Federal	$	26	$	(1)	$	25	$	25	$	—	$	25
State	1		—		1		1		—		1
Foreign	(17)		(1)		(18)		(15)		—		(15)
Total	$	10	$	(2)	$	8	$	11	$	—	$	11

During 2022, the Company recorded valuation allowances totaling $2 million related to certain deferred tax assets as management believes that it is not "more likely than not" that the Company will realize the assets.

At December 31, 2022, the Company had U.S. federal and state NOLs of approximately $1.5 billion and $0.5 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 $32 million. If not utilized, the Company's U.S. federal NOLs expire starting in 2025 and ending in 2036, the state NOLs started expiring in 2022 and end in 2036, and the foreign NOLs expire starting in 2023 and ending in 2036. 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.

As of December 31, 2022, there were no unrecognized tax benefits that would impact the effective tax rate, if recognized.

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 Internal Revenue Service examination.

On April 26, 2021, the Company entered into an agreement in principle with the Australian Taxation Office ("ATO") to pay A$83 million to settle the previously disclosed outstanding audit of the Australian tax consequences of the Company’s 2015 sale of Crown Castle Australia Holdings Pty Ltd ("CCAL"), formerly a 77.6% owned Australian subsidiary of the Company ("ATO Settlement"). The sale of CCAL generated approximately $1.2 billion in net proceeds to the Company, and resulted in a gain from the disposal of discontinued operations of $979 million for the year ended December 31, 2015.

On June 16, 2021, the Company entered into a definitive settlement agreement with the ATO evidencing the ATO Settlement. On July 1, 2021, the Company paid approximately $62 million (A$83 million), based on the exchange rate in effect on that date, pursuant to the ATO Settlement. The Company recognized the ATO Settlement as a charge within discontinued

operations in its consolidated statement of operations and comprehensive income (loss) for the year ended December 31, 2021, as this amount represented a reduction to the gain from the disposal of discontinued operations previously reported during the year ended December 31, 2015. The Company reflected the payment pursuant to the ATO Settlement within discontinued operations in the Company's consolidated statement of cash flows for the year ended December 31, 2021.

The Company regularly assesses the likelihood of additional assessments in each of the tax jurisdictions in which it has business operations. The Company has no uncertain tax positions as of December 31, 2022. Additionally, the Company does not believe any such additional assessments arising from other examinations or audits will have a material effect on the Company's financial statements.

As of December 31, 2022, the Company's deferred tax assets are included in "Other assets, net" and the Company's deferred tax liabilities are included in "Other long-term liabilities" on the Company's consolidated balance sheet.