In response to the COVID-19 pandemic, many governments have enacted or are contemplating measures to provide aid and economic stimulus. These measures may include deferring the due dates of tax payments or other changes to their income and non-income-based tax laws. The Coronavirus Aid, Relief, and Economic Security Act (CARES Act), which was enacted on March 27, 2020 in the U.S., includes measures to assist companies, including allowing net operating losses originating in 2018, 2019, or 2020 to be carried back up to five years. During 2020, we elected to carry back losses to 2014 and accordingly recognized a $117 million tax benefit.

The provision or benefit for income taxes is comprised of the following:


	2020		2019		2018
Current:
U.S.	$	(59)	$	(12)	$	63
Foreign	458		443		444
Total current	399		431		507
Deferred:
U.S.	11		(12)		(211)
Foreign	149		63		(38)
Total deferred	160		51		(249)
Provision for income taxes	$	559	$	482	$	258

The provision for income taxes differs from the amount computed by applying the U.S. statutory income tax rate to the loss or income before income taxes for the reasons set forth below for the years ended December 31:


	2020		2019		2018
Income (loss) before income taxes, inclusive of equity in loss of affiliate	$	(15,202)	$	753	$	541
Taxes at the U.S. federal statutory income tax rate	(3,192)		158		114
Impact of goodwill impairment	3,102		—		—
Effect of foreign operations	183		85		103
Tax impact of partnership structure	(33)		17		80


Change in valuation allowances	494		241		87
CARES Act	(117)		—		—
Tax Cuts and Jobs Act enactment	—		—		(107)
Other - net	122		(19)		(19)
Provision for income taxes	$	559	$	482	$	258
Actual income tax rate	(3.7)%		64.0%		47.7%

Deferred income taxes reflect the net tax effects of temporary differences between the carrying amounts of assets and liabilities for financial reporting purposes and the amounts used for income tax purposes, as well as operating loss and tax credit carryforwards.


	2020		2019
Deferred tax assets:
Operating loss carryforwards	$	2,249	$	1,654
Tax credit carryforwards	1,083		941
Investment in partnership	160		381
Goodwill and other intangibles	143		117
Employee benefits	138		98
Property	127		137
Receivables	53		79
Inventory	51		91
Other	264		317
Total deferred income tax asset	4,268		3,815
Valuation allowances	(3,472)		(2,883)
Total deferred income tax asset after valuation allowance	796		932
Deferred tax liabilities:
Other	(29)		(29)
Total deferred income tax liability	(29)		(29)
Net deferred tax asset	$	767	$	903

At December 31, 2020, we had approximately $402 million of non-U.S. tax credits which may be carried forward indefinitely under applicable foreign law, $521 million of U.S. foreign tax credits and $160 million of other credits, the majority of which will expire after tax year 2027 under U.S. tax law. Additionally, we had $2,249 million of net operating loss carryforwards, of which approximately $347 million will expire within five years, $960 million will expire between 6 years and 20 years, and the remainder can be carried forward indefinitely.

We record a valuation allowance when it is more likely than not that some portion or all of the deferred tax assets will not be realized. The ultimate realization of the deferred tax assets depends on the ability to generate sufficient taxable income of the appropriate character in the future and in the appropriate taxing jurisdictions. At December 31, 2020, $3,472 million of valuation allowances are recorded against various deferred tax assets, including foreign net operating losses (NOL) of $1,657 million, U.S. federal and foreign tax credit carryforwards of $924 million, other U.S. NOL's and tax credit carryforwards of $452 million, and certain other U.S. and foreign deferred tax assets of $439 million. There are $319 million of deferred tax assets related to foreign net operating loss carryforwards without a valuation allowance as we expect that the deferred tax assets will be realized within the carryforward period.

Indefinite reinvestment is determined by management’s intentions concerning the future operations of the Company. In cases where repatriation would otherwise incur significant withholding or income taxes, these earnings have been indefinitely reinvested in the company's active non-U.S. business operations. As of December 31, 2020, the cumulative amount of undistributed foreign earnings is approximately $6 billion. Computation of the potential deferred tax liability associated with these undistributed earnings and any other basis differences is not practicable.

At December 31, 2020, we had $483 million of tax liabilities for total gross unrecognized tax benefits related to uncertain tax positions. In addition to these uncertain tax positions, we had $95 million and $23 million related to interest and penalties, respectively, for total liabilities of $601 million for uncertain positions. If we were to prevail on all uncertain positions, the net effect would result in an income tax benefit of approximately $523 million. The remaining $77 million comprised of $53 million for deferred tax assets that represent tax benefits that would be received in different taxing jurisdictions or in a different character in the event that we did not prevail on all uncertain tax positions and increased valuation allowances of $24 million.


Asset / (Liability)	2020		2019
Balance at beginning of year	$	(451)	$	(472)
Additions for tax positions of the current year	(71)		(25)
Additions for tax positions of prior years	(31)		(27)
Reductions for tax positions of prior years	35		55
Settlements with tax authorities	12		6
Lapse of statute of limitations	23		12
Balance at end of year	$	(483)	$	(451)

It is expected that the amount of unrecognized tax benefits will change in the next twelve months due to expiring statutes, audit activity, tax payments, and competent authority proceedings related to transfer pricing or final decisions in matters that are the subject of litigation in various taxing jurisdictions in which we operate. At December 31, 2020, we had approximately $57 million of tax liabilities related to uncertain tax positions, each of which are individually insignificant, and each of which are reasonably possible of being settled within the next twelve months.

We conduct business in more than 120 countries and are subject to income taxes in most taxing jurisdictions in which we operate, each of which may have multiple open years subject to examination. All Internal Revenue Service examinations have been completed and closed through 2016 for the most significant U.S. returns. We believe that we have made adequate provision for all income tax uncertainties.