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INCOME TAXES
12 Months Ended
Oct. 31, 2021
INCOME TAXES  
INCOME TAXES

9. INCOME TAXES

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

  

2021

  

2020

  

2019

 

Current:

             

             

             

U.S.:

Federal

$

899

$

400

$

545

State

 

183

 

53

 

72

Foreign

 

1,017

 

640

 

700

Total current

 

2,099

 

1,093

 

1,317

Deferred:

U.S.:

Federal

 

(303)

 

(68)

 

(345)

State

 

(45)

 

9

 

(26)

Foreign

 

(93)

 

48

 

(94)

Total deferred

 

(441)

 

(11)

 

(465)

Provision for income taxes

$

1,658

$

1,082

$

852

Based upon the location of the company’s operations, the consolidated income before income taxes in the U.S. in 2021, 2020, and 2019 was $4,061 million, $2,082 million, and $2,166 million, respectively, and in foreign countries was $3,541 million, $1,801 million, and $1,922 million, respectively. Certain foreign operations are branches or partnerships of Deere & Company and are subject to U.S. as well as foreign income tax regulations. The pretax income by location and the preceding analysis of the income tax provision by taxing jurisdiction are not directly related.

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

  

2021

  

2020

  

2019

 

U.S. federal income tax provision at the U.S. statutory rate (21 percent)

$

1,597

$

815

$

859

State and local taxes, net of federal effect

119

59

47

Other Impacts of Tax Cuts and Jobs Act of 2017

(85)

39

(101)

Rate differential on foreign subsidiaries

 

148

 

106

 

89

Research and business tax credits

 

(48)

 

(50)

 

(85)

Excess tax benefits on equity compensation

(79)

(87)

(40)

Valuation allowances

 

18

 

139

 

28

Other - net

 

(12)

61

55

Provision for income taxes

$

1,658

$

1,082

$

852

At October 31, 2021, accumulated earnings in certain subsidiaries outside the U.S. totaled $2,155 million. A provision for foreign withholding taxes has not been made since these earnings are expected to remain indefinitely reinvested outside the U.S. Determination of the amount of a foreign withholding tax liability on these unremitted earnings is not practicable.

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 the deferred income tax assets and liabilities at October 31, 2021 and November 1, 2020 in millions of dollars follows:

2021

2020

 Deferred 

 Deferred 

 Deferred 

 Deferred 

Tax

Tax

Tax

Tax

 

Assets

 

Liabilities

 

Assets

 

Liabilities

 

OPEB liabilities

$

676

$

804

Lessor lease transactions

$

399

$

489

Tax loss and tax credit carryforwards

 

1,542

 

937

Accrual for sales allowances

 

466

 

362

Tax over book depreciation

154

196

Goodwill and other intangible assets

 

337

 

368

Pension - net

 

448

 

316

Allowance for credit losses

 

78

 

81

Accrual for employee benefits

 

298

 

249

Share-based compensation

 

53

 

41

Deferred compensation

 

49

 

40

Lessee lease transactions

46

43

56

56

Unearned revenue

172

 

22

 

Other items

 

333

 

341

 

344

 

305

Less valuation allowances

 

(1,530)

 

(858)

Deferred income tax assets and liabilities

$

2,183

$

1,722

$

2,394

$

1,414

Deere & Company files a consolidated federal income tax return in the U.S., which includes the wholly-owned financial services subsidiaries. These subsidiaries account for income taxes generally as if they filed separate income tax returns, with a modification for realizability of certain tax benefits.

At October 31, 2021, tax loss and tax credit carryforwards of $1,542 million were available with $1,068 million expiring from 2022 through 2041 and $474 million with an indefinite carryforward period.

A reconciliation of the total amounts of unrecognized tax benefits at October 31, 2021, November 1, 2020, and November 3, 2019 in millions of dollars follows:

  

2021

  

2020

  

2019

 

Beginning of year balance

$

668

$

553

$

279

Increases to tax positions taken during the current year

 

81

 

63

 

30

Increases to tax positions taken during prior years

 

100

 

95

 

357

Decreases to tax positions taken during prior years

 

(23)

 

(30)

 

(30)

Decreases due to lapse of statute of limitations

 

(12)

 

(9)

 

(6)

Settlements

 

(3)

 

(1)

 

(75)

Foreign exchange

 

 

(3)

 

(2)

End of year balance

$

811

$

668

$

553

The amount of unrecognized tax benefits at October 31, 2021 and November 1, 2020 that would impact the effective tax rate if the tax benefits were recognized was $227 million and $134 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 U.S. Internal Revenue Service (IRS) has completed the examination of the company’s federal income tax returns for periods prior to 2015. The federal income tax returns for years 2015, 2016, and 2017 are currently under examination. Various state and foreign income tax returns, including major tax jurisdictions in Argentina, Australia, Brazil, Canada, China, Finland, France, Germany, India, Luxembourg, Mexico, Russia, Singapore, and Spain also remain subject to examination by taxing authorities.

The company’s policy is to recognize interest related to income taxes in interest expense and interest income and recognize penalties in selling, administrative and general expenses. During 2021 and 2019, the total amount of expense from interest and penalties was $7 million and $13 million. During 2020, interest and penalties previously recorded were reversed when tax positions were effectively settled resulting in a $3 million net benefit. The interest income in 2021, 2020, and 2019 was $8 million, $11 million, and $25 million, respectively. At October 31, 2021 and November 1, 2020, the liability for accrued interest and penalties totaled $75 million and $72 million, respectively, and the receivable for interest was $11 million and $6 million, respectively.