Income Taxes

Income before income tax and the provision for income tax consist of the following (in millions):



Years ended December 31	2014			2013			2012
Income before income taxes:
U.K.	$	347		$	96		$	36
U.S.	(55		)	349			468
Other	1,473			1,093			876
Total	$	1,765		$	1,538		$	1,380
Income tax expense (benefit):
Current:
U.K.	$	1		$	(18	)	$	(10	)
U.S. federal	156			111			170
U.S. state and local	75			52			57
Other	236			259			238
Total current tax expense	$	468		$	404		$	455
Deferred tax expense (benefit):
U.K.	$	38		$	43		$	46
U.S. federal	(133		)	(48		)	(83		)
U.S. state and local	(24		)	10			(10		)
Other	(15		)	(19		)	(48		)
Total deferred tax benefit	$	(134	)	$	(14	)	$	(95	)
Total income tax expense	$	334		$	390		$	360

Income before income taxes shown above is based on the location of the business unit to which such earnings are attributable for tax purposes. In addition, because the earnings shown above may in some cases be subject to taxation in more than one country, the income tax provision shown above as U.K., U.S. or Other may not correspond to the geographic attribution of the earnings.

A reconciliation of the income tax provisions based on the Company's domicile and statutory rate at each reporting period is performed. The 2014, 2013 and 2012 reconciliations are based on the U.K. statutory corporate tax rate of 21.5%, 23%, and 24%, respectively. The reconciliation to the provisions reflected in the Consolidated Financial Statements is as follows:



Years ended December 31	2014	2013	2012
Statutory tax rate	21.5%	23.0%	24.0%
U.S. state income taxes, net of U.S. federal benefit	1.5	2.6	2.2
Taxes on international operations (1)	(8.9)	(4.4)	0.6
Nondeductible expenses	1.7	1.4	2.0
Adjustments to prior year tax requirements	0.9	0.1	(1.3)
Deferred tax adjustments, including statutory rate changes	(0.7)	1.4	0.7
Deferred tax adjustments, international earnings	1.0	3.3	—
Adjustments to valuation allowances	0.6	(1.7)	(5.6)
Change in uncertain tax positions	1.7	(0.3)	3.1
Other — net	(0.4)	—	0.4
Effective tax rate	18.9%	25.4%	26.1%

(1)

The Company determines the adjustment for taxes on international operations based on the difference between the statutory tax rate applicable to earnings in each foreign jurisdiction and the enacted rate of 21.5%, 23% and 24% at December 31, 2014, 2013 and 2012, respectively. In 2014 and 2013, the benefit to the Company's effective income tax rate from taxes on international operations relates to benefits from lower-taxed global operations, primarily due to the use of global funding structures.

The components of the Company's deferred tax assets and liabilities are as follows (in millions):



As of December 31	2014			2013
Deferred tax assets:
Employee benefit plans	$	739		$	623
Net operating/capital loss and tax credit carryforwards	295			354
Other accrued expenses	44			48
Investment basis differences	45			50
Accrued interest	303			94
Other	46			58
Total	1,472			1,227
Valuation allowance on deferred tax assets	(205		)	(127		)
Total	$	1,267		$	1,100
Deferred tax liabilities:
Intangibles and property, plant and equipment	$	(1,058	)	$	(1,074	)
Unremitted earnings	(28		)	(51		)
Deferred revenue	(28		)	(27		)
Other accrued expenses	(40		)	(39		)
Unrealized investment gains	(8		)	—
Unrealized foreign exchange gains	(44		)	(27		)
Other	(20		)	(64		)
Total	$	(1,226	)	$	(1,282	)
Net deferred tax asset (liability)	$	41		$	(182	)

Deferred income taxes (assets and liabilities have been netted by jurisdiction) have been classified in the Consolidated Statements of Financial Position as follows (in millions):



As of December 31,	2014			2013
Deferred tax assets — current (1)	$	212		$	93
Deferred tax assets — non-current	144			193
Deferred tax liabilities — current (1)	(2		)	(48		)
Deferred tax liabilities — non-current	(313		)	(420		)
Net deferred tax asset (liability)	$	41		$	(182	)


(1)	Included in Other current assets and Other current liabilities.

Valuation allowances have been established primarily with regard to the tax benefits of certain net operating loss, capital loss and interest expense carryforwards. Valuation allowances increased by $78 million in 2014, primarily attributable to increases in the valuation allowance related to capital loss and interest expense carryforwards.

The Company recognized, as an adjustment to additional paid-in-capital, income tax benefits attributable to employee stock compensation of $89 million, $74 million and $33 million in 2014, 2013 and 2012, respectively.

During 2014 the Company changed its assertion on a portion of undistributed earnings and U.S. deferred income taxes of $28 million were accrued. Undistributed earnings of non-U.S. entities were approximately $2.2 billion at December 31, 2014. U.S. income taxes have not been provided on these undistributed earnings because they are considered to be permanently invested in those subsidiaries. It is not practicable to estimate the amount of unrecognized deferred tax liabilities, if any, for these undistributed foreign earnings.

At December 31, 2014 and 2013, the Company had U.K. operating loss carryforwards of $154 million and $660 million and capital loss carryforwards of $380 million and $270 million, respectively. In addition, at December 31, 2014 and 2013, the Company had U.S. federal operating loss carryforwards of $18 million and $25 million, and U.S. state operating loss carryforwards of $451 million and $412 million, respectively. In other non-U.S. jurisdictions, the Company had operating loss carryforwards of $325 million and $287 million and capital loss carryforwards of $223 million and $86 million as of December 31, 2014 and 2013, respectively. The UK operating losses and capital losses have an indefinite carryforward. The federal operating loss carryforwards as of December 31, 2014 expire at various dates from 2020 to 2030 and the state operating loss carryforwards as of December 31, 2014 expire at various dates from 2015 to 2034. Operating and capital losses, in other non-U.S. jurisdictions have various carryforward periods and will begin to expire in 2015.

During 2012, the Company was granted a tax holiday for the period from October 1, 2012 through September 30, 2022, with respect to withholding taxes and certain income derived from services in Singapore. This tax holiday and reduced withholding tax rate may be extended when certain conditions are met or may be terminated early if certain conditions are not met. The benefit realized was approximately $7 million and $3 million during the years ended December 31, 2014 and 2013, respectively. No benefit was realized for the year ended December 31, 2012. The diluted earnings per share impact of this tax holiday was $0.02, $0.01, and $0.00 during the years ended December 31, 2014, 2013, and 2012, respectively.

Uncertain Tax Positions

The following is a reconciliation of the Company's beginning and ending amount of uncertain tax positions (in millions):



	2014			2013
Balance at January 1	$	164		$	156
Additions based on tax positions related to the current year	31			22
Additions for tax positions of prior years	10			69
Reductions for tax positions of prior years	(6		)	(70		)
Settlements	—			(10		)
Business combinations	5			—
Lapse of statute of limitations	(11		)	(3		)
Foreign currency translation	(2		)	—
Balance at December 31	$	191		$	164

The Company's liability for uncertain tax positions as of December 31, 2014, 2013, and 2012, includes $154 million, $141 million, and $156 million, respectively, related to amounts that would impact the effective tax rate if recognized. It is possible that the amount of unrecognized tax benefits may change in the next twelve months; however, we do not expect the change to have a significant impact on our consolidated statements of income or consolidated balance sheets. These changes may be the result of settlements of ongoing audits. At this time, an estimate of the range of the reasonably possible outcomes within the twelve months cannot be made.

The Company recognizes interest and penalties related to uncertain tax positions in its provision for income taxes. Aon accrued potential interest and penalties of $4 million, $2 million, and $6 million in 2014, 2013, and 2012, respectively. The Company recorded a liability for interest and penalties of $31 million, $27 million, and $23 million as of December 31, 2014, 2013, and 2012, respectively.

The Company and its subsidiaries file income tax returns in their respective jurisdictions. The Company has substantially concluded all U.S. federal income tax matters for years through 2007. Material U.S. state and local income tax jurisdiction examinations have been concluded for years through 2005. The Company has concluded income tax examinations in its primary non-U.S. jurisdictions through 2005.