INCOME TAXES

The income tax provision (benefit) differed from amounts computed at the statutory federal income tax rate and consisted of the following significant components, as follows (in millions):



UAL	2018			2017 (a)			2016 (a)
Income tax provision at statutory rate	$	558		$	1,064		$	1,320
State income taxes, net of federal income tax benefit	29			30			38
Foreign tax rate differential	(84		)	(43		)	—
Global intangible low-taxed income	4			—			—
Foreign income taxes	2			3			3
Nondeductible employee meals	12			17			16
Impact of Tax Act	(5		)	(179		)	—
Income tax adjustment from AOCI (b)	—			—			180
State rate change	3			12			(12		)
Valuation allowance	(3		)	(16		)	20
Other, net	13			8			(26		)
	$	529		$	896		$	1,539

Current	$	14		$	(77	)	$	(92	)
Deferred	515			973			1,631
	$	529		$	896		$	1,539

United	2018			2017 (a)			2016 (a)
Income tax provision at statutory rate	$	559		$	1,065		$	1,321
State income taxes, net of federal income tax	29			30			38
Foreign tax rate differential	(84		)	(43		)	—
Global intangible low-taxed income	4			—			—
Foreign income taxes	2			3			3
Nondeductible employee meals	12			17			16
Impact of Tax Act	(5		)	(196		)	—
Income tax adjustment from AOCI (b)	—			—			180
State rate change	3			12			(12		)
Valuation allowance	(3		)	(16		)	20
Other, net	12			7			(25		)
	$	529		$	879		$	1,541

Current	$	14		$	(77	)	$	(92	)
Deferred	515			956			1,633
	$	529		$	879		$	1,541

(a) Amounts adjusted due to the adoption of Accounting Standards Update No. 2014-09, Revenue from Contracts with Customers (Topic 606). See Note 1 to the financial statements contained in Part II, Item 8 of this report for additional information.

(b) Prior to the release of the deferred income tax valuation allowance in the third quarter of 2015, the Company recorded approximately $465 million of valuation allowance adjustments in AOCI. Subsequent to the release of the deferred income tax valuation allowance in 2015, the $465 million debit remained within AOCI, of which $180 million related to losses on fuel hedges designated for hedge accounting and $285 million related to pension and other postretirement liabilities. Accounting rules required the adjustments to remain in AOCI as long as the Company had fuel derivatives designated for cash flow hedge accounting and the Company continues to provide pension and postretirement benefits. In 2016, the Company settled all of its fuel hedges and has not entered into any new fuel derivative contracts for hedge accounting. Accordingly, the Company reclassified the $180 million to income tax expense in 2016.

The Company's effective tax rate for the year ended December 31, 2018 differed from the federal statutory rate of 21% due to a blend of federal, state and foreign taxes as well as the impact of certain nondeductible items.

On December 22, 2017, Congress enacted the Tax Act, which made significant changes to U.S. federal income tax laws, including reducing the corporate rate from 35% to 21% effective January 1, 2018. In December 2017, the SEC issued Staff Accounting Bulletin No. 118 ("SAB 118"), which allowed the Company to record provisional amounts related to the impact of the Tax Act and to adjust those amounts during a measurement period not to extend more than one year from the date of enactment. Based on our current interpretation of the Tax Act and published Treasury and Internal Revenue Service ("IRS") guidance as of December 31, 2018, the Company's accounting for the impacts of the Tax Act is complete and the Company has not recorded any material adjustments to the provisional amounts under SAB 118. In 2018, we recorded an income tax benefit for the one-time transition tax of $4 million and have completed the re-measurement of our net deferred tax balances. The Tax Act included a Global Intangible Low-Taxed Income ("GILTI") provision which introduced a new tax on foreign income in excess of a deemed return on tangible business property of foreign subsidiaries. The GILTI provisions of the Tax Act became effective for the Company during 2018 and we elected to account for it in the period incurred (the "period cost method").

Temporary differences and carryforwards that give rise to deferred tax assets and liabilities at December 31, 2018 and 2017 were as follows (in millions):



	UAL						United
	2018			2017			2018			2017
Deferred income tax asset (liability):
Federal and state net operating loss ("NOL") carryforwards	$	398		$	601		$	372		$	574
Deferred revenue	1,232			1,090			1,232			1,090
Employee benefits, including pension, postretirement and medical	885			1,051			885			1,051
Other	408			351			406			351
Less: Valuation allowance	(59		)	(63		)	(59		)	(63		)
Total deferred tax assets	$	2,864		$	3,030		$	2,836		$	3,003

Depreciation	$	(2,929	)	$	(2,431	)	$	(2,929	)	$	(2,431	)
Intangibles	(749		)	(803		)	(749		)	(803		)
Total deferred tax liabilities	$	(3,678	)	$	(3,234	)	$	(3,678	)	$	(3,234	)
Net deferred tax liability	$	(814	)	$	(204	)	$	(842	)	$	(231	)

United and its domestic consolidated subsidiaries file a consolidated federal income tax return with UAL. Under an intercompany tax allocation policy, United and its subsidiaries compute, record and pay UAL for their own tax liability as if they were separate companies filing separate returns. In determining their own tax liabilities, United and each of its subsidiaries take into account all tax credits or benefits generated and utilized as separate companies and they are each compensated for the aforementioned tax benefits only if they would be able to use those benefits on a separate company basis.

The Company's federal and state NOL carryforwards relate to prior years' NOLs, which may be used to reduce tax liabilities in future years. These tax benefits are mostly attributable to federal pre-tax NOL carryforwards of $1.6 billion for UAL. If not utilized these federal pre-tax NOLs will expire as follows (in billions): $0.6 in 2030, $1.0 thereafter. In addition, for UAL the majority of tax benefits of the state NOLs of $83 million will expire over a five to twenty year period. We have recorded a $48 million valuation allowance against these state NOLs.

The Company's unrecognized tax benefits related to uncertain tax positions were $39 million, $21 million and $74 million at December 31, 2018, 2017 and 2016, respectively. Included in the ending balance at December 31, 2018 is $39 million that would affect the Company's effective tax rate if recognized. The changes in unrecognized tax benefits relating to settlements with taxing authorities, unrecognized tax benefits as a result of tax positions taken during a prior period and unrecognized tax benefits relating from a lapse of the statute of limitations were immaterial during 2018, 2017 and 2016. The Company does not expect significant increases or decreases in their unrecognized tax benefits within the next 12 months. There are no material amounts included in the balance at December 31, 2018 for tax positions for which the ultimate deductibility is highly certain but for which there is uncertainty about the timing of such deductibility.

The Company's federal income tax returns for tax years after 2002 remain subject to examination by the IRS and state taxing jurisdictions. Currently, there are no ongoing examinations of the Company's prior year tax returns being conducted by the IRS.