INCOME TAXES

12 Months Ended

Dec. 31, 2021

Income Tax Disclosure [Abstract]

Income Taxes

INCOME BEFORE TAXES

	Years Ended December 31,
	2021			2020			2019
U.S.		$	3,955		$	3,318		$	4,178
Non-U.S.		3,280			2,694			3,381
		$	7,235		$	6,012		$	7,559

TAX EXPENSE (BENEFIT)

	Years Ended December 31,
	2021			2020			2019
Tax expense (benefit) consists of
Current:
U.S. Federal		$	415		$	475		$	8
U.S. State		146			79			43
Non-U.S.		886			768			1,099
		$	1,447		$	1,322		$	1,150
Deferred:
U.S. Federal		$	173		$	234		$	332
U.S. State		37			39			63
Non-U.S.		(32)			(448)			(216)
		178			(175)			179
		$	1,625		$	1,147		$	1,329

	Years Ended December 31,
	2021			2020			2019
The U.S. federal statutory income tax rate is reconciled to the effective income tax rate as follows:
U.S. federal statutory income tax rate		21.0	%		21.0	%		21.0	%
Taxes on non-U.S. earnings(1)(2)		(1.4)			(0.8)			(0.5)
U.S. state income taxes(1)		1.5			1.3			1.1
Reserves for tax contingencies		2.2			(2.6)			2.0
Employee share-based payments		(0.7)			(1.2)			(1.2)
Reduction of certain receivables		—			2.0			—
U.S. Tax Cuts and Jobs Act		—			—			(3.6)
Restructuring		(1.4)			—			—
U.S. Valuation Allowance		2.0			0.1			—
All other items—net		(0.7)			(0.7)			(1.2)
		22.5	%		19.1	%		17.6	%

(1)Net of changes in valuation allowance

(2)Includes U.S. taxes on non-U.S. earnings

The effective tax rate increased by 3.4 percentage points in 2021 compared to 2020. The increase was primarily due to the establishment of a valuation allowance for deferred tax assets not expected to be realized, incremental tax reserves, a lower tax benefit from restructuring and the absence of prior year items including tax benefits realized as a result of the favorable resolution of a foreign tax matter related to the spin-off transactions, tax law changes in India and the resolution of certain U.S. tax matters offset by a non-cash charge related to the reduction of the aggregate carrying value of certain receivables with no corresponding tax benefit. The Company’s non-U.S. effective tax rate was 26.0%, an increase of approximately 14.1 percentage points compared to 2020. The increase in the foreign effective tax rate was primarily attributable to incremental tax reserves, the tax impact of restructuring and the absence of prior year items including the favorable resolution of a foreign tax matter related to the previously completed spin-off transactions and tax law changes in India.

The effective tax rate increased by 1.5 percentage points in 2020 compared to 2019. The increase was primarily attributable to accrued withholding taxes related to unremitted foreign earnings and non-cash charges related to the reduction of the aggregate carrying value of certain receivables with no corresponding tax benefit, offset by the favorable resolution of a foreign tax matter related to the previously completed spin-off transactions, tax impact of restructuring, tax law changes in India, and the resolution of certain U.S. tax matters. The Company’s non-U.S. effective tax rate was 11.9%, a decrease of approximately 14.2 percentage points compared to 2019. The decrease in the foreign effective tax rate was primarily attributable to the favorable resolution of a foreign tax matter related to the previously completed spin-off transactions, tax impact of restructuring, and tax law changes in India offset by accrued withholding taxes related to unremitted foreign earnings.

DEFERRED TAX ASSETS (LIABILITIES)

The tax effects of temporary differences and tax carryforwards which give rise to future income tax benefits and payables are as follows:

Deferred tax assets:	December 31,
	2021			2020
Postretirement benefits other than pensions		$	77		$	85
Asbestos and environmental		468			508
Employee compensation and benefits		174			180
Lease liabilities		242			197
Other accruals and reserves		260			110
Net operating and capital losses		734			779
Capital loss limitation and carryover		151			—
Tax credit carryforwards		164			219
Gross deferred tax assets		2,270			2,078
Valuation allowance		(857)			(766)
Total deferred tax assets		$	1,413		$	1,312
Deferred tax liabilities:
Pension		$	(948)		$	(548)
Property, plant and equipment		(464)			(437)
Right-of-use asset		(230)			(184)
Intangibles		(883)			(898)
Unremitted earnings of foreign subsidiaries		(426)			(398)
Other asset basis differences		(334)			(169)
Other		(2)			(31)
Total deferred tax liabilities		(3,287)			(2,665)
Net deferred tax liability		$	(1,874)		$	(1,353)

The Company's gross deferred tax assets include $901 million related to non-U.S. operations comprised principally of net operating losses, capital loss and tax credit carryforwards, primarily in Canada, France, Germany, Luxembourg, and the United Kingdom, and deductible temporary differences. The Company maintains a valuation allowance of $703 million against a portion of the non-U.S. gross deferred tax assets. Additionally, a valuation allowance of $150 million was established against the U.S. gross deferred tax asset for capital losses generated from restructuring transactions during the year. The change in the valuation allowance resulted in an increase of $124 million, increase of $105 million, and a decrease of $23 million to income tax expense in 2021, 2020 and 2019, respectively. In the event the Company determines that it will not be able to realize its net deferred tax assets in the future, the Company will reduce such amounts through an increase to income tax expense in the period such determination is made. Conversely, if the Company determines that it will be able to realize net deferred tax assets in excess of the carrying amounts, the Company will decrease the recorded valuation allowance through a reduction to income tax expense in the period that such determination is made.

As of December 31, 2021, the Company recorded a $426 million deferred tax liability on all unremitted foreign earnings based on estimated earnings and profits of approximately $17.1 billion as of the balance sheet date.

As of December 31, 2021, the Company's net operating loss, capital loss and tax credit carryforwards were as follows:

Jurisdiction	Expiration Period	Net Operating and Capital Loss Carryforwards			Tax Credit Carryforwards
U.S. Federal	2040		$	684		$	97
U.S. State	2040		390			21
Non-U.S.	2041		466			50
Non-U.S.	Indefinite		2,185			—
			$	3,725		$	168

Many jurisdictions impose limitations on the timing and utilization of net operating loss and tax credit carryforwards. In those instances, whereby there is an expected permanent limitation on the utilization of the net operating loss or tax credit carryforward, the deferred tax asset and amount of the carryforward have been reduced.

	Years Ended December 31,
	2021			2020			2019
Change in unrecognized tax benefits:
Balance at beginning of year		$	991		$	1,164		$	1,089
Gross increases related to current period tax positions		93			94			51
Gross increases related to prior periods tax positions		39			68			83
Gross decreases related to prior periods tax positions		(27)			(256)			(34)
Decrease related to resolutions of audits with tax authorities		(1)			(35)			(3)
Expiration of the statute of limitations for the assessment of taxes		(12)			(76)			(13)
Foreign currency translation		(22)			32			(9)
Balance at end of year		$	1,061		$	991		$	1,164

As of December 31, 2021, 2020 and 2019, there were $1,061 million, $991 million, and $1,164 million, respectively, of unrecognized tax benefits that if recognized would be recorded as a component of Tax expense.

The following table summarizes tax years that remain subject to examination by major tax jurisdictions as of December 31, 2021:

Jurisdiction	Open Tax Years Based on Originally Filed Returns
	Examination in progress	Examination not yet initiated
U.S. Federal	2017-2018	2019-2021
U.S. State	2013-2019	2017-2021
Australia	n/a	2018-2021
Canada(1)	2015-2018	2019-2021
China	2011-2020	2021
France	2018-2020	2021
Germany(1)	2009-2018	2019-2021
India	1999-2020	2021
Italy	2012-2018	2019-2021
Netherlands	n/a	2018-2021
Switzerland(1)	2016-2018	2019-2021
United Kingdom	2013-2019	2020-2021

(1)Includes provincial or similar local jurisdictions, as applicable.

Based on the outcome of these examinations, or as a result of the expiration of statute of limitations for specific jurisdictions, it is reasonably possible that certain unrecognized tax benefits for tax positions taken on previously filed tax returns will materially change from those recorded as liabilities in the Company's financial statements. In addition, the outcome of these examinations may impact the valuation of certain deferred tax assets (such as net operating losses) in future periods.

Unrecognized tax benefits for examinations in progress were $592 million, $556 million, and $413 million, as of December 31, 2021, 2020 and 2019, respectively. Estimated interest and penalties related to the underpayment of income taxes are classified as a component of Tax expense in the Consolidated Statement of Operations and totaled $79 million, $80 million, and $73 million for the years ended December 31, 2021, 2020 and 2019, respectively. Accrued interest and penalties were $580 million, $507 million, and $487 million, as of December 31, 2021, 2020 and 2019, respectively.