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Income and Other Taxes
12 Months Ended
Dec. 31, 2020
Income Tax Disclosure [Abstract]  
Income and Other Taxes Income and Other Taxes
Income before income taxes and equity income (pre-tax income) from continuing operations was as follows:
Year Ended December 31,
 202020192018
Domestic income$353 $679 $331 
Foreign (loss) income(101)143 218 
Income before Income Taxes and Equity Income$252 $822 $549 
The components of Income tax expense from continuing operations were as follows:
Year Ended December 31,
 202020192018
Federal Income Taxes
Current$$(3)$37 
Deferred58 98 83 
Foreign Income Taxes
Current19 43 46 
Deferred(34)57 
State Income Taxes
Current15 29 
Deferred10 21 (5)
Income Tax Expense$64 $179 $247 
A reconciliation of the U.S. federal statutory income tax rate to the consolidated effective income tax rate was as follows:
Year Ended December 31,
 202020192018
U.S. federal statutory income tax rate21.0 %21.0 %21.0 %
Nondeductible expenses4.1 %1.3 %3.7 %
Effect of tax law changes(10.5)%(4.6)%14.5 %
Change in valuation allowance for deferred tax assets9.9 %2.0 %0.6 %
State taxes, net of federal benefit5.5 %3.5 %2.3 %
Audit and other tax return adjustments1.4 %0.6 %(1.8)%
Tax-exempt income, credits and incentives(5.9)%(2.1)%(2.2)%
Foreign rate differential adjusted for U.S. taxation of foreign profits(1)
(2.6)%0.1 %4.8 %
Stock-based compensation2.3 %(0.3)%0.2 %
Other0.2 %0.3 %1.9 %
Effective Income Tax Rate25.4 %21.8 %45.0 %
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(1)The “U.S. taxation of foreign profits” represents the U.S. tax, net of foreign tax credits, associated with actual and deemed repatriations of earnings from our non-U.S. subsidiaries.
On a consolidated basis, including discontinued operations, we paid a total of $32, $94 and $80 in income taxes to federal, foreign and state jurisdictions during the three years ended December 31, 2020, 2019 and 2018, respectively.
Total income tax expense (benefit) was allocated to the following items:
Year Ended December 31,
 202020192018
Pre-tax income$64 $179 $247 
Discontinued operations(1)
— 95 10 
Common shareholders' equity:
Changes in defined benefit plans43 (55)131 
Cash flow hedges(1)
Translation adjustments(3)(9)
Retained Earnings— — 36 
Total Income Tax Expense$105 $226 $420 
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(1)Refer to Note 6 - Divestitures for additional information regarding discontinued operations.
Unrecognized Tax Benefits and Audit Resolutions
We recognize tax liabilities when, despite our belief that our tax return positions are supportable, we believe that certain positions may not be fully sustained upon review by tax authorities. Each period, we assess uncertain tax positions for recognition, measurement and effective settlement. Benefits from uncertain tax positions are measured at the largest amount of benefit that is greater than 50 percent likely of being realized upon settlement - the more-likely-than-not recognition threshold. Where we have determined that our tax return filing position does not satisfy the more likely than not recognition threshold, we have recorded no tax benefits. These assessments require the use of considerable estimates and judgments and can increase or decrease our effective tax rate, as well as impact our operating results. A difference in the ultimate resolution of uncertain tax positions from what is currently estimated could have a material impact on our results of operations and financial condition.
The calculation of our tax liabilities involves dealing with uncertainties in the application of complex tax laws and regulations in a variety of jurisdictions. We are also subject to ongoing tax examinations in numerous jurisdictions due to the extensive geographical scope of our operations. As a result, we have received, and may in the future receive, proposed tax adjustments and tax assessments in multiple jurisdictions. We regularly assess the likelihood of the outcomes resulting from these ongoing tax examinations as part of our continuing assessment of uncertain tax positions to determine our provision for income taxes. The specific timing of when the resolution of each tax position will be reached is uncertain. As of December 31, 2020, we do not believe that there are any positions for which it is reasonably possible that the total amount of unrecognized tax benefits will significantly increase or decrease within the next 12 months.
A reconciliation of the beginning and ending amount of unrecognized tax benefits is as follows:
202020192018
Balance at January 1$127 $108 $125 
Additions related to current year42 
Additions related to prior years positions17 
Reductions related to prior years positions(10)(36)(13)
Settlements with taxing authorities(1)
(8)(1)(6)
Reductions related to lapse of statute of limitations(7)(3)(3)
Currency— — 
Balance at December 31$115 $127 $108 
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(1)The majority of settlements did not result in the utilization of cash.
Included in the balances at December 31, 2020, 2019 and 2018 are $8, $3 and $8, respectively, of tax positions that are highly certain of realizability but for which there is uncertainty about the timing or that they may be reduced through an indirect benefit from other taxing jurisdictions. Because of the impact of deferred tax accounting, other than for the possible incurrence of interest and penalties, the disallowance of these positions would not affect the annual effective tax rate.
Within income tax expense, we recognize interest and penalties accrued on unrecognized tax benefits, as well as interest received from favorable settlements. We had $4, $2 and $2 accrued for the payment of interest and penalties associated with unrecognized tax benefits at December 31, 2020, 2019 and 2018, respectively.
In the U.S., we are no longer subject to U.S. federal income tax examinations for years before 2015. With respect to our major foreign jurisdictions, we are no longer subject to tax examinations by tax authorities for years before 2011.
Deferred Income Taxes
At December 31, 2020 we have not provided deferred taxes on our undistributed pre-1987 E&P of approximately $360, as such undistributed earnings have been determined to be indefinitely reinvested and we currently do not plan to initiate any action that would precipitate a deferred tax impact. The increase from the amount at December 31, 2019 of $350 is due to foreign currency translation adjustments. Additionally, we have also not provided deferred taxes on the outside basis differences in our investments in foreign subsidiaries that are unrelated to undistributed earnings. These basis differences are also indefinitely reinvested. A determination of the unrecognized deferred taxes related to these components is not practicable.
The tax effects of temporary differences that give rise to significant portions of the deferred taxes were as follows:
December 31,
 2020
2019(2)
Deferred Tax Assets  
Research and development$150 $143 
Post-retirement medical benefits94 98 
Net operating losses377 389 
Operating reserves, accruals and deferrals124 115 
Tax credit carryforwards249 231 
Deferred and share-based compensation13 26 
Pension211 298 
Depreciation35 16 
Operating lease liabilities82 84 
Other44 63 
Subtotal1,379 1,463 
Valuation allowance(396)(399)
Total$983 $1,064 
Deferred Tax Liabilities
Finance lease and installment sales$247 $240 
Intangibles and goodwill140 128 
Unremitted earnings of foreign subsidiaries31 39 
Operating lease ROU assets76 78 
Other16 18 
Total$510 $503 
Total Deferred Taxes, Net$473 $561 
Reconciliation to the Consolidated Balance Sheets
Deferred tax assets$508 $598 
Deferred tax liabilities(1)
(35)(37)
Total Deferred Taxes, Net$473 $561 
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(1)Represents the deferred tax liabilities recorded in Other long-term liabilities - refer to Note 15 - Supplementary Financial Information.
(2)The deferred tax assets and liabilities disclosure at December 31, 2019 has been adjusted to primarily reflect the tax effect of the gross deferred tax Operating Lease (ROU) Assets and the tax effect of the related gross deferred tax Operating lease liabilities recognized in accordance with ASC 842. There was no impact on Total Deferred Taxes, Net from this adjustment.
We record the estimated future tax effects of temporary differences between the tax bases of assets and liabilities and the amounts reported, as well as net operating loss and tax credit carryforwards. Deferred tax assets are assessed for realizability and, where applicable, a valuation allowance is recorded to reduce the total deferred tax asset to an amount that will, more-likely-than-not, be realized in the future. We apply judgment in assessing the realizability of these deferred tax assets and the need for any valuation allowances. In determining the amount of deferred tax assets that are more-likely-than-not to be realized, we considered historical profitability, projected future taxable income, the expected timing of the reversals of existing temporary differences and tax planning strategies. The deferred tax assets requiring significant judgment are U.S. tax credit carryforwards with a limited life.
The net change in the total valuation allowance for the years ended December 31, 2020, 2019 and 2018 was a decrease of $3, an increase of $2 and a decrease of $38, respectively. The valuation allowance relates primarily to certain net operating loss carryforwards, tax credit carryforwards and deductible temporary differences for which we have concluded it is more-likely-than-not that these items will not be realized in the ordinary course of operations.
Although realization is not assured, we have concluded that it is more-likely-than-not that the deferred tax assets, for which a valuation allowance was determined to be unnecessary, will be realized in the ordinary course of operations based on the available positive and negative evidence, including scheduling of deferred tax liabilities and projected income from operating activities. The amount of the net deferred tax assets considered realizable, however, could change in the near term if future income or income tax rates are higher or lower than currently estimated, or if there are differences in the timing or amount of future reversals of existing taxable or deductible temporary differences.
At December 31, 2020, we had tax credit carryforwards of $249 available to offset future income taxes, of which $2 are available to carryforward indefinitely while the remaining $247 will expire 2021 through 2041 if not utilized. We also had net operating loss carryforwards for income tax purposes of $600 that will expire 2021 through 2041, if not utilized, and $1.7 billion available to offset future taxable income indefinitely.