
Years ended December 31	2020		2019		2018
Income (loss) before income taxes:
Ireland	$	(86)	$	200	$	208
U.K.	634		228		(240)
U.S.	(29)		(219)		(601)
Other	1,946		1,662		1,879
Total	$	2,465	$	1,871	$	1,246
Income tax expense:
Current:
Ireland	$	2	$	1	$	2
U.K.	30		20		21
U.S. federal	126		22		101
U.S. state and local	22		41		35
Other	259		249		212
Total current tax expense	$	439	$	333	$	371
Deferred tax expense (benefit):
Ireland	$	(1)	$	(1)	$	(1)
U.K.	39		35		19
U.S. federal	(72)		(20)		(165)
U.S. state and local	(4)		(27)		(56)
Other	47		(23)		(22)
Total deferred tax expense (benefit)	$	9	$	(36)	$	(225)
Total income tax expense	$	448	$	297	$	146

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 Ireland, U.K., U.S. or Other may not correspond to the geographic attribution of the earnings.

The Company performs a reconciliation of the income tax provisions based on its domicile and statutory rate at each reporting period. Due to the Ireland Reorganization, the 2020 reconciliation is based on the Irish statutory corporate tax rate of 25.0%, while the 2019 and 2018 reconciliations are based on the U.K. statutory corporate tax rate of 19.0% and 19.0%, respectively. The reconciliation to the provisions from continuing operations reflected in the Consolidated Financial Statements is as follows:


Years ended December 31	2020	2019	2018
Statutory tax rate	25.0%	19.0%	19.0%
U.S. state income taxes, net of U.S. federal benefit	1.0	0.5	(0.4)
Taxes on international operations (1) (4)	(9.8)	(6.0)	(7.3)
Nondeductible expenses	2.1	1.6	2.7
Adjustments to prior year tax requirements (4)	—	0.1	0.9
Deferred tax adjustments, including statutory rate changes	0.7	—	—
Deferred tax adjustments, international earnings	0.7	—	—
Adjustments to valuation allowances	—	1.8	3.8
Change in uncertain tax positions	1.5	2.2	0.9
Excess tax benefits related to shared based compensation (2)	(2.2)	(2.8)	(3.6)
U.S. Tax Reform impact (3)	—	(0.3)	7.1
Loss on disposition	—	—	(10.2)
Capital Losses	(1.8)	—	—
Non-deductible transaction costs	1.3	—	—
Other — net	(0.3)	(0.2)	(1.2)
Effective tax rate	18.2%	15.9%	11.7%

(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 25.0%, 19.0% and 19.0% at December 31, 2020, 2019, and 2018, respectively. 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 and the tax holiday in Singapore.

(3)The impact of the Tax Reform Act including the Transition Tax, the re-measurement of U.S. deferred tax assets and liabilities from 35% to 21%, withholding tax accruals, and the allocation of tax benefit between continuing operations and discontinued operations related to utilization of foreign tax credits.

(4)In July 2020, final U.S. tax regulations were issued regarding the global intangible low-tax income (“GILTI”) high tax election, allowing taxpayers to exclude from GILTI the income of a Controlled Foreign Corporation that incurs a foreign tax rate more than 90% of the top U.S. corporate tax rate. A GILTI high tax election may be made on an annual basis, and taxpayers may choose to apply the election to taxable years beginning after December 31, 2017. The Company expects to make the GILTI high-tax election for 2020 and 2019 and therefore recorded the impact of making the election for both years.

The Company has elected to account for global intangible low-taxed income (“GILTI”) in the period in which it is incurred, and therefore has not provided deferred tax impacts of GILTI in its Consolidated Financial Statements.


As of December 31	2020		2019
Deferred tax assets:
Net operating loss, capital loss, interest, and tax credit carryforwards	$	653	$	440
Employee benefit plans	312		373
Lease liabilities	248		247
Other accrued expenses	103		68
Deferred revenue	36		24
Investment basis differences	28		28
Lease and service guarantees	2		3
Accrued interest	—		116
Other	54		57
Total	1,436		1,356
Valuation allowance on deferred tax assets	(205)		(200)
Total	$	1,231	$	1,156
Deferred tax liabilities:
Intangibles and property, plant and equipment	$	(291)	$	(251)
Lease right-of-use asset	(211)		(219)
Deferred costs	(141)		(128)
Unremitted earnings	(37)		(28)
Unrealized foreign exchange gains	(26)		(26)
Other accrued expenses	(22)		(25)
Other	(41)		(33)
Total	$	(769)	$	(710)
Net deferred tax asset	$	462	$	446

In assessing the realizability of deferred tax assets, the Company considers whether it is more likely than not that some portion or all of the deferred tax assets will not be realized and adjusts the valuation allowance accordingly. Considerations with respect to the realizability of deferred tax assets include the period of expiration of the deferred tax asset, historical earnings and projected future taxable income by jurisdiction as well as tax liabilities for the tax jurisdiction to which the tax asset relates. Significant management judgment is required in determining the assumptions and estimates related to the amount and timing of future taxable income. Valuation allowances have been established primarily with regard to the tax benefits of certain net operating loss, capital loss, and interest carryforwards. Valuation allowances increased by $5 million as of December 31, 2020, when compared to December 31, 2019. The change is primarily attributable to an increase in valuation allowances related to capital losses carryforwards offset by the release of the valuation allowance related to certain interest carryforwards.

The Company generally intends to limit distributions from foreign subsidiaries to earnings previously taxed in the U.S., primarily as a result of the Transition Tax or GILTI, or to repatriations that would otherwise not generate a U.S. tax liability. As of December 31, 2020, the Company has accrued $37 million for local country income taxes, withholding taxes and state income taxes on those undistributed earnings that are not indefinitely reinvested. The Company has not provided for deferred taxes on outside basis differences in our investments in our foreign subsidiaries that are unrelated to these accumulated undistributed earnings, as these outside basis differences are indefinitely reinvested. A determination of the unrecognized deferred taxes related to these other components of our outside basis differences is not practicable.


As of December 31	2020		2019
U.K.
Operating loss carryforwards	$	266	$	438
Capital loss carryforwards	$	577	$	411
Interest carryforwards	$	121	$	203

U.S.
Federal operating loss carryforwards	$	49	$	1
Federal capital loss carryforwards	$	112	$	112
Federal interest carryforwards	$	1,220	$	355

State operating loss carryforwards	$	378	$	376
State capital loss carryforwards	$	123	$	123
State interest carryforwards	$	573	$	172

Other Non-U.S.
Operating loss carryforwards	$	400	$	308
Capital loss carryforwards	$	42	$	29
Interest carryforwards	$	34	$	159

The U.K. operating losses, capital losses, and interest carryforward each have an indefinite carryforward period. The federal operating loss carryforwards generated through December 31, 2017 expire at various dates between 2034 and 2036 while federal operating loss carryforwards generated after this date have indefinite carryforward periods. State net operating losses as of December 31, 2020 have various carryforward periods and will begin to expire in 2021. Federal and state capital losses can be carried forward until 2023. Federal and state interest carryforwards have indefinite carryforward periods. Operating and capital losses in other non-U.S. jurisdictions have various carryforward periods and will begin to expire in 2021. The interest carryforwards in other non-U.S. jurisdictions have various carryforward periods and will begin to expire in 2025.

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 $97 million, $90 million, and $77 million during the years ended December 31, 2020, 2019, and 2018, respectively. The impact of this tax holiday on diluted earnings per share was $0.42, $0.37, and $0.31 during the years ended December 31, 2020, 2019, and 2018, respectively.


	2020		2019
Balance at January 1	$	299	$	279
Additions based on tax positions related to the current year	25		23
Additions for tax positions of prior years	7		12
Reductions for tax positions of prior years	(3)		(5)
Settlements	—		(5)
Business combinations	—		—
Lapse of statute of limitations	(7)		(5)
Foreign currency translation	—		—
Balance at December 31	$	321	$	299

The Company’s liability for uncertain tax positions as of December 31, 2020, 2019, and 2018, includes $270 million, $248 million, and $228 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, the Company does not expect the change to have a significant impact on its 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. The Company accrued potential interest and penalties of $21 million, $24 million, and $22 million in 2020, 2019, and 2018, respectively. The Company recorded a liability for interest and penalties of $120 million, $99 million, and $77 million as of December 31, 2020, 2019, and 2018, 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 2008. The Company has concluded income tax examinations in its primary non-U.S. jurisdictions through 2008.