Note 15. Income Taxes

The taxable income of the Company is included in the consolidated U.S. income tax return of Deere & Company. Provisions for income taxes are made generally as if Capital Corporation and each of its subsidiaries filed separate income tax returns.

The provision for income taxes by taxing jurisdiction and by significant component consisted of the following (in millions of dollars):


	2016		2015		2014
Current:
U.S.:
Federal	$	(119.0)	$	119.1	$	274.4
State		4.4		5.4		7.9
Foreign		17.1		20.1		21.2
Total current		(97.5)		144.6		303.5

Deferred:
U.S.:
Federal		273.4		121.2		(33.7)
State		(.7)		1.7		.6
Foreign		5.1		2.4		(9.8)
Total deferred		277.8		125.3		(42.9)
Provision for income taxes	$	180.3	$	269.9	$	260.6

A comparison of the statutory and effective income tax provision and reasons for related differences follows (in millions of dollars):


	2016		2015		2014
U.S. federal income tax provision at a statutory rate of 35 percent	$	182.0	$	268.4	$	281.0
Increase (decrease) resulting from:
Municipal lease income not taxable		(1.4)		(1.4)		(1.4)
Tax rates on foreign earnings		(5.9)		(6.0)		(8.0)
Foreign tax benefit						(23.1)
State and local income taxes, net of federal income tax benefit		2.4		4.6		5.5
Other – net		3.2		4.3		6.6
Provision for income taxes	$	180.3	$	269.9	$	260.6

At October 31, 2016, accumulated earnings in certain subsidiaries outside the U.S. totaled $360.7 million for which no provision for U.S. income taxes or foreign withholding taxes has been made, because it is expected that such earnings will be reinvested outside the U.S. indefinitely. Determination of the amount of unrecognized deferred tax liability on these unremitted earnings is not practicable. At October 31, 2016, the amount of cash and cash equivalents held by these foreign subsidiaries was $85.0 million.

Deferred income taxes arise because there are certain items that are treated differently for financial accounting than for income tax reporting purposes. An analysis of deferred income tax assets and liabilities at October 31 was as follows (in millions of dollars):


	2016				2015
	Deferred		Deferred		Deferred		Deferred
	Tax		Tax		Tax		Tax
	Assets		Liabilities		Assets		Liabilities
Lease transactions			$	789.9			$	505.4
Tax over book depreciation				12.0				9.7
Deferred retail note finance income				5.4				6.2
Allowance for credit losses	$	53.6			$	45.3
Accrual for retirement and other benefits		26.3				27.4
Federal taxes on deferred state tax deductions		14.6				14.1
Tax loss and tax credit carryforwards		20.8				11.8
Miscellaneous accruals and other		8.3		.2		17.6
Less valuation allowances		(1.8)				(1.1)
Deferred income tax assets and liabilities	$	121.8	$	807.5	$	115.1	$	521.3

At October 31, 2016, certain tax loss and tax credit carryforwards of $20.8 million were available, with $17.1 million expiring from 2017 through 2036 and $3.7 million with an indefinite carryforward period.

A reconciliation of the total amounts of unrecognized tax benefits at October 31 was as follows (in millions of dollars):


	2016		2015		2014
Beginning of year balance	$	36.0	$	36.2	$	33.6
Increases to tax positions taken during the current year		9.7		11.1		12.1
Increases to tax positions taken during prior years		1.1		1.6		.7
Decreases to tax positions taken during prior years		(7.3)		(7.8)		(7.0)
Decreases due to lapse of statute of limitations		(3.0)		(3.9)		(3.2)
Settlements				(1.1)
Foreign exchange				(.1)
End of year balance	$	36.5	$	36.0	$	36.2

The amount of unrecognized tax benefits at October 31, 2016 and 2015 that would affect the effective tax rate if the tax benefits were recognized was $19.0 million and $19.2 million, respectively. The remaining liability was related to tax positions for which there are offsetting tax receivables, or the uncertainty was only related to timing. The Company expects that any reasonably possible change in the amounts of unrecognized tax benefits in the next twelve months would not be significant.

The Company files its tax returns according to the tax laws of the jurisdictions in which it operates, which includes the U.S. federal jurisdiction, and various state and foreign jurisdictions. The Company is included in the consolidated U.S. income tax return and various state returns of Deere & Company. The U.S. Internal Revenue Service has completed the examination of Deere & Company’s federal income tax returns for periods prior to 2009. The years’ 2009 through 2014 federal income tax returns are currently under examination. Various state and foreign income tax returns also remain subject to examination by taxing authorities.

The Company’s policy is to recognize interest related to income taxes in interest expense and other income, and recognize penalties in administrative and operating expenses. During 2016, 2015 and 2014, the total amount of expense from interest and penalties was $1.8 million, $1.4 million and $1.7 million and the interest income was not material for any of the periods. At October 31, 2016 and 2015, the liability for accrued interest and penalties totaled $16.8 million and $15.8 million, respectively.