INCOME TAXES

We incur income taxes on the earnings of our U.S. and foreign operations. The following table, based on the locations of the taxable entities from which sales were derived (rather than the location of customers), presents the U.S. and foreign components of our income before income taxes:



	2013		2014		2015
United States	$	751	$	797	$	912
Foreign	114		150		90
	$	865	$	947	$	1,002

The income shown above was determined according to GAAP. Because those standards sometimes differ from the tax rules used to calculate taxable income, there are differences between: (a) the amount of taxable income and pretax financial income for a year; and (b) the tax bases of assets or liabilities and their amounts as recorded in our financial statements. As a result, we recognize a current tax liability for the estimated income tax payable on the current tax return, and deferred tax liabilities (income tax payable on income that will be recognized on future tax returns) and deferred tax assets (income tax refunds from deductions that will be recognized on future tax returns) for the estimated effects of the differences mentioned above.

Deferred tax assets and liabilities as of the end of each of the last two years were as follows:



	2014			2015
April 30,
Deferred tax assets:
Postretirement and other benefits	$	139		$	164
Accrued liabilities and other	30			22
Inventories	8			12
Loss and credit carryforwards	52			46
Valuation allowance	(34		)	(27		)
Total deferred tax assets, net	195			217
Deferred tax liabilities:
Intangible assets	(184		)	(207		)
Property, plant, and equipment	(49		)	(61		)
Other	(21		)	(31		)
Total deferred tax liabilities	(254		)	(299		)
Net deferred tax liability	$	(59	)	$	(82	)

As of April 30, 2015, the gross amounts of loss carryforwards include a $34 net operating loss in Brazil (no expiration); a U.K. non-trading loss of $36 (no expiration); a $28 net operating loss in Finland (expires in varying amounts in 2024 and 2025); a $26 net operating loss in Mexico (expires in varying amounts between 2016 and 2018); and other foreign net operating losses of $27 ($8 that do not expire and $19 that expire in varying amounts between 2016 and 2025).

The $27 valuation allowance at April 30, 2015 ($34 at April 30, 2014), relates primarily to a $12 net operating loss in Brazil which decreased $7 in 2015 due to adjustments to certain prior year net operating losses as a result of filing amended returns, partially offset by an increase in current year net operating losses. Although the Brazil losses can be carried forward indefinitely, it is uncertain that we will realize sufficient taxable income to allow us to use these losses. The valuation allowance also includes $8 ($7 at April 30, 2014) related to other foreign net operating losses that expire between 2016 and 2023. The remaining valuation allowance relates to a $7 ($8 at April 30, 2014) non-trading loss carryforward in the United Kingdom that was generated during 2009. Although the non-trading losses can be carried forward indefinitely, we know of no significant transactions that will let us use them.

During 2014, we deferred a tax benefit of $95 that resulted primarily from the release of certain deferred tax liabilities in connection with an intercompany transfer of assets, composed primarily of an intangible asset. We are amortizing the deferred benefit to tax expense over approximately six years for financial reporting purposes, in accordance with Accounting Standard Codification (ASC) 740-10-25-3(e) (Income Taxes) and ASC 810-45-8 (Consolidation), resulting in a tax benefit of $5 and $15 for 2014 and 2015, respectively. The remaining balance of the deferred benefit, which is included in “other liabilities” on the accompanying balance sheet, was $75 as of April 30, 2015. This intercompany transfer of assets also resulted in a taxable gain that is primarily responsible for the increase in our accrued taxes balance from April 30, 2013, to April 30, 2014. The tax on this gain was paid in 2015 and was primarily responsible for the decrease in our accrued taxes balance from April 30, 2014.

Deferred tax liabilities were not provided on undistributed earnings of foreign subsidiaries ($797 and $803 at April 30, 2014 and 2015, respectively) because we expect these undistributed earnings to be reinvested indefinitely outside the United States. If these amounts were not considered permanently reinvested, additional deferred tax liabilities of approximately $175 and $163 would have been provided as of April 30, 2014 and 2015, respectively.

Total income tax expense for a year includes the tax associated with the current tax return (“current tax expense”) and the change in the net deferred tax asset or liability (“deferred tax expense”). Our total income tax expense for each of the last three years was as follows:



	2013		2014			2015
Current:
U.S. federal	$	197	$	243		$	259
Foreign	41		49			42
State and local	10		1			11
	248		293			312
Deferred:
U.S. federal	$	23	$	3		$	15
Foreign	1		(6		)	(11		)
State and local	2		(2		)	2
	26		(5		)	6
	$	274	$	288		$	318

Our consolidated effective tax rate usually differs from current statutory rates due to the recognition of amounts for events or transactions with no tax consequences. The following table reconciles our effective tax rate to the federal statutory tax rate in the United States:



	Percent of Income Before Taxes
	2013		2014		2015
U.S. federal statutory rate	35.0	%	35.0	%	35.0	%
State taxes, net of U.S. federal tax benefit	1.0	%	0.7	%	1.0	%
Income taxed at other than U.S. federal statutory rate	(1.4	)%	(2.2	)%	(0.5	)%
Tax benefit from U.S. manufacturing	(2.1	)%	(2.8	)%	(2.5	)%
Amortization of deferred tax benefit from intercompany transactions	—	%	(0.4	)%	(1.6	)%
Other, net	(0.8	)%	0.2	%	0.3	%
Effective rate	31.7	%	30.5	%	31.7	%

At April 30, 2015, we had $13 of gross unrecognized tax benefits, $8 of which would reduce our effective income tax rate if recognized. A reconciliation of the beginning and ending unrecognized tax benefits follows:



	2013			2014			2015
Unrecognized tax benefits at beginning of year	$	13		$	11		$	11
Additions for tax positions provided in prior periods	2			1			2
Additions for tax positions provided in current period	1			1			1
Decreases for tax positions provided in prior years	(1		)	(1		)	(1		)
Settlements of tax positions in the current period	(3		)	(1		)	—
Lapse of statutes of limitations	(1		)	—			—
Unrecognized tax benefits at end of year	$	11		$	11		$	13

We file income tax returns in the United States, including several state and local jurisdictions, as well as in several other countries in which we conduct business. The major jurisdictions and their earliest fiscal years that are currently open for tax examinations are 2006 for one state in the United States; 2013 in the United Kingdom; 2011 in Australia and Ireland; 2010 in Brazil and the Netherlands; 2009 in Poland and Finland; and 2004 in Mexico. The audits of our fiscal 2013 and 2014 U.S. federal tax returns were concluded in the first quarters of fiscal 2015 and 2016, respectively. In addition, we are participating in the Internal Revenue Service’s Compliance Assurance Program for our fiscal 2015 tax year.

We believe there will be no material change in our gross unrecognized tax benefits in the next 12 months.