The liabilities for income taxes reflected in our Consolidated Balance Sheets are as follows (in millions).

	December 31,
	2019		2018
Currently payable	$	24	$	323
Deferred		65,823		50,503
Other		952		549
	$	66,799	$	51,375

On December 22, 2017, President Trump signed into law legislation known as the Tax Cuts and Jobs Act of 2017 (“TCJA”). Among its provisions, the TCJA reduced the statutory U.S. Corporate income tax rate from 35% to 21% effective January 1, 2018. The TCJA also provided for a one-time tax on certain accumulated undistributed post-1986 earnings of foreign subsidiaries. Further, the TCJA includes provisions that, in certain instances, impose U.S. income tax liabilities on earnings of foreign subsidiaries and limit the deductibility of interest expenses. The TCJA also provides for accelerated deductions of certain capital expenditures made after September 27, 2017 through bonus depreciation.

In 2017, upon the enactment of the TCJA, we recorded a reduction in our deferred income tax liabilities of approximately $35.6 billion for the effect of the reduction in the U.S. statutory income tax rate. As a result, we recorded an income tax benefit of approximately $29.6 billion and we increased regulatory liabilities of our regulated utility subsidiaries by approximately $6.0 billion for the portion of the deferred income tax liability reduction that we will be required to, effectively, refund to customers in the rate setting process. We also recognized an income tax charge of approximately $1.4 billion with respect to the deemed repatriation of the accumulated undistributed post-1986 earnings of our foreign subsidiaries. Thus, upon the enactment of the TCJA, we included a net income tax benefit in our 2017 earnings of approximately $28.2 billion. In 2018, we reduced our estimate of the income taxes on the deemed repatriation of earnings of foreign subsidiaries and recognized additional deferred income tax rate change effects.

The tax effects of temporary differences that give rise to significant portions of deferred tax assets and deferred tax liabilities are shown below (in millions).

	December 31,
	2019			2018
Deferred tax liabilities:
Investments – unrealized appreciation and cost basis differences	$	32,134		$	17,765
Deferred charges reinsurance assumed		2,890			2,970
Property, plant and equipment and equipment held for lease		29,388			28,279
Goodwill and other intangible assets		7,293			7,199
Other		3,144			3,187
		74,849			59,400
Deferred tax assets:
Unpaid losses and loss adjustment expenses		(1,086	)		(1,238	)
Unearned premiums		(853	)		(767	)
Accrued liabilities		(1,981	)		(1,956	)
Regulatory liabilities		(1,610	)		(1,673	)
Other		(3,496	)		(3,263	)
		(9,026	)		(8,897	)
Net deferred tax liability	$	65,823		$	50,503

We have not established deferred income taxes on accumulated undistributed earnings of certain foreign subsidiaries, which are expected to be reinvested indefinitely. Repatriation of all accumulated earnings of foreign subsidiaries would be impracticable to the extent that such earnings represent capital to support normal business operations. Generally, no U.S. federal income taxes will be imposed on future distributions of foreign earnings under current law. However, distributions to the U.S. or other foreign jurisdictions could be subject to withholding and other local taxes.

Income tax expense reflected in our Consolidated Statements of Earnings for each of the three years ending December 31, 2019 is as follows (in millions).

	2019		2018			2017
Federal	$	19,069	$	(1,613	)	$	(23,427	)
State		625		175			894
Foreign		1,210		1,117			1,018
	$	20,904	$	(321	)	$	(21,515	)

Current	$	5,818	$	5,176		$	3,299
Deferred		15,086		(5,497	)		(24,814	)
	$	20,904	$	(321	)	$	(21,515	)

Income tax expense is reconciled to hypothetical amounts computed at the U.S. federal statutory rate for each of the three years ending December 31, 2019 in the table below (in millions).

	2019			2018			2017
Earnings before income taxes	$	102,696		$	4,001		$	23,838

Hypothetical income tax expense computed at the U.S. federal statutory rate	$	21,566		$	840		$	8,343
Dividends received deduction and tax-exempt interest		(433	)		(393	)		(905	)
State income taxes, less U.S. federal income tax benefit		494			138			465
Foreign tax rate differences		(6	)		271			(339	)
U.S. income tax credits		(942	)		(711	)		(636	)
Net benefit from the enactment of the TCJA		—			(302	)		(28,200	)
Other differences, net		225			(164	)		(243	)
	$	20,904		$	(321	)	$	(21,515	)

We file income tax returns in the United States and in state, local and foreign jurisdictions. We have settled income tax liabilities with the U.S. federal taxing authority (“IRS”) for tax years through 2011. The IRS is auditing Berkshire’s consolidated U.S. federal income tax returns for the 2012 through 2016 tax years. We are also under audit or subject to audit with respect to income taxes in many state and foreign jurisdictions. It is reasonably possible that certain of these income tax examinations will be settled in 2020. We currently do not believe that the outcome of unresolved issues or claims will be material to our Consolidated Financial Statements.

At December 31, 2019 and 2018, net unrecognized tax benefits were $952 million and $549 million, respectively. Included in the balance at December 31, 2019, were $795 million of tax positions that, if recognized, would impact the effective tax rate. The remaining balance in net unrecognized tax benefits principally relates to tax positions where the ultimate recognition is highly certain but there is uncertainty about the timing of recognition. Because of the impact of deferred income tax accounting, these positions, when recognized, would not affect the annual effective income tax rate. In 2019, we recorded income tax expense of $377 million for uncertain tax positions related to investments by a subsidiary in certain tax equity investment funds that generated income tax benefits from 2015 through 2018. We now believe that it is more likely than not those income tax benefits are not valid. As of December 31, 2019, we do not expect any material increases to the estimated amount of unrecognized tax benefits in the next twelve months.