Income/(loss) before provision for income taxes based on geographic location is disclosed in the table below:



	For the Years Ended December 31,
	2019		2018		2017
Income/(loss) before provision for income taxes:
United States	$	65,370	$	44,527	$	(6,595	)
Foreign	234,156		205,246		180,900
Total	$	299,526	$	249,773	$	174,305

The provision for income taxes consists of the following:



	For the Years Ended December 31,
	2019			2018			2017
Current
Federal	$	16,943		$	10,814		$	65,571
State	3,610			4,123			(204		)
Foreign	25,680			42,580			23,617
Deferred
Federal	(9,425		)	(37,785		)	7,235
State	(358		)	(3,548		)	(90		)
Foreign	2,019			(6,667		)	5,416
Total	$	38,469		$	9,517		$	101,545

The U.S. Tax Act significantly changed U.S. corporate income tax laws including a reduction of the U.S. corporate income tax rate from 35.0% to 21.0% effective January 1, 2018 and the creation of a territorial tax system with a one-time transition tax on accumulated foreign subsidiary earnings not previously subject to U.S. income tax. In addition, the U.S. Tax Act created new taxes on certain foreign-sourced earnings and certain related party payments, which are referred to as GILTI and the base erosion and anti-abuse tax (“BEAT”), respectively.

Due to the timing of the enactment and the complexity involved in applying the provisions of the U.S. Tax Act, the Company made reasonable estimates of the effects and recorded provisional amounts in its financial statements as of December 31, 2017. During the year ended December 31, 2018, the Company completed its analysis of the impact of the U.S. Tax Act and recorded the following adjustments to the recorded provisional amounts:

In 2017, the Company reassessed its accumulated foreign earnings in light of the U.S. Tax Act and determined $97,000 of its accumulated earnings in Belarus were no longer indefinitely reinvested. As a result, the Company recorded a charge of $4,850 in the provision for income taxes during the year ended December 31, 2017 for the withholding tax payable to Belarus when the earnings are distributed. In 2018, the Company remitted this full amount of accumulated earnings as dividends and also remitted as dividends certain earnings of its foreign subsidiaries in Canada, Cyprus, Ireland and Russia and additional earnings in Belarus. Based on proposed tax regulations issued by the U.S. Department of the Treasury during 2018, it was determined that an offsetting U.S. foreign tax credit could be claimed for the withholding tax paid to Belarus resulting in a net $4,850 income tax benefit recognized during the year ended December 31, 2018.

As of December 31, 2019, the Company has determined that all accumulated undistributed foreign earnings of $861,893 are expected to be indefinitely reinvested. Due to the enactment of the U.S. Tax Act and the one-time transition tax on accumulated foreign subsidiary earnings, these accumulated foreign earnings are no longer expected to be subject to U.S. federal income tax if repatriated but could be subject to state and foreign income and withholding taxes.

The reconciliation of the provision for income taxes at the federal statutory income tax rate to the Company’s effective income tax rate is as follows:



	For the Years Ended December 31,
	2019			2018			2017
Provision for income taxes at federal statutory rate	$	62,898		$	52,452		$	61,007
Increase/(decrease) in taxes resulting from:
Impact from U.S. Tax Act	—			(4,009		)	74,632
Entity classification election deferred tax asset impact	—			(25,962		)	—
GILTI and BEAT U.S. taxes	(926		)	1,526			—
Excess tax benefits relating to stock-based compensation	(28,385		)	(17,370		)	(9,307		)
Subsidiary withholding tax liability and related foreign tax credit	—			(4,850		)	4,850
Foreign tax expense and tax rate differential	(1,402		)	(88		)	(39,997		)
Effect of permanent differences	3,264			2,724			3,205
State taxes, net of federal benefit	2,971			3,452			(116		)
Change in valuation allowance	218			151			783
Stock-based compensation expense	571			652			6,908
Other	(740		)	839			(420		)
Provision for income taxes	$	38,469		$	9,517		$	101,545

The Company’s worldwide effective tax rate for years ended December 31, 2019, 2018 and 2017 was 12.8%, 3.8% and 58.3%, respectively. The provision for income taxes in the year ended December 31, 2018 was favorably impacted by the recognition of $25,962 of net deferred tax assets resulting from the Company’s decision to change the tax status and to classify most of its foreign subsidiaries as disregarded for U.S. income tax purposes. This change subjects the income of the disregarded foreign subsidiaries to U.S. income taxation, resulting in a reduced foreign tax rate differential benefit in 2019 and 2018 as compared to 2017. In addition, the Company recorded excess tax benefits upon vesting or exercise of stock-based awards of $28,385, $17,370 and $9,307 during the years ended December 31, 2019, 2018 and 2017, respectively.

In Belarus, member technology companies of High-Technologies Park, including the Company’s local subsidiary, have a full exemption from Belarus income tax on qualifying income through January 2049. However, beginning February 1, 2018, the earnings of the Company’s Belarus local subsidiary became subject to U. S. income taxation due to the Company’s decision to change the tax status of the subsidiary. Consequently, there was less income tax benefit from the Belarus tax exemption for the year ended December 31, 2018 compared to the previous year. There was no aggregate dollar benefit derived from this tax holiday for the year ended December 31, 2019, and the aggregate dollar benefits derived from this tax holiday approximated $1,352 and $15,503 for the years ended December 31, 2018 and 2017, respectively. There was no impact on diluted net income per share for the year ended December 31, 2019. The benefit the tax holiday had on diluted net income per share approximated $0.02 and $0.28 for the years ended December 31, 2018 and 2017, respectively.

Deferred income taxes reflect the net effects of temporary differences between the carrying amounts of assets and liabilities for financial reporting purposes and the amounts used for income tax purposes. Significant components of the Company’s deferred tax assets and liabilities are as follows:



	As of December 31, 2019			As of December 31, 2018
Deferred tax assets:
Property and equipment	$	5,329		$	4,531
Intangible assets	574			1,262
Accrued expenses	41,457			32,067
Net operating loss carryforward	5,168			4,983
Deferred revenue	3,510			5,802
Stock-based compensation	29,596			27,558
Operating lease liabilities	7,438			—
Foreign tax credit	3,491			—
Foreign currency exchange	2,499			5,772
Other assets	1,533			782
Deferred tax assets	$	100,595		$	82,757
Less: valuation allowance	(3,877		)	(3,189		)
Total deferred tax assets	$	96,718		$	79,568

Deferred tax liabilities:
Property and equipment	$	4,981		$	1,480
Intangible assets	11,364			5,582
Operating lease right-of-use assets	6,900			—
Accrued revenue and expenses	2,176			1,540
U.S. taxation of foreign subsidiaries	—			3,000
Other liabilities	812			933
Total deferred tax liabilities	$	26,233		$	12,535
Net deferred tax assets	$	70,485		$	67,033

Included in the stock-based compensation expense deferred tax asset at December 31, 2019 and 2018 is $6,788 and $7,561, respectively, that is related to acquisitions and is amortized for tax purposes over a 10 to 15-year period.

As of December 31, 2019, the Company’s domestic and foreign net operating loss (“NOL”) carryforwards for income tax purposes were approximately $3,712 and $25,487, respectively. If not utilized, the domestic NOL carryforwards will begin to expire in 2021. The foreign NOL carryforwards include $9,311 from jurisdictions with no expiration date, with the remainder expiring as follows: $274 in 2020, $5,805 in 2021, $6,273 in 2022, $1,371 in 2023, $2,204 in 2024, and $249 beyond 2024. The Company maintains a valuation allowance primarily related to the net operating loss carryforwards in certain foreign jurisdictions that the Company believes are not likely to be realized, which totaled $21,948 as of December 31, 2019.

As of December 31, 2019 and 2018, unrecognized tax benefits of $2,904 and $1,432, respectively, are included in Income taxes payable, noncurrent within the consolidated balance sheets. There were no significant new tax positions that resulted in unrecognized tax benefits or reversals of prior year tax positions during the years ended December 31, 2019, 2018 and 2017. There were no tax positions for which it was reasonably possible that unrecognized tax benefits will significantly increase or decrease within twelve months of the reporting date.

The Company files income tax returns in the United States and in various state, local and foreign jurisdictions. The Company’s significant tax jurisdictions are the United States, Russia, Germany, Ukraine, the United Kingdom, Hungary, Switzerland, Netherlands, Poland and India. The tax years subsequent to 2015 remain open to examination by the United States Internal Revenue Service and generally, the tax years subsequent to 2015 remain open to examination by various state and local taxing authorities and various foreign taxing authorities.