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Income Taxes
 12 Months Ended
Dec. 31, 2023
Income Tax Disclosure [Abstract]  
Income Taxes Income Taxes
(Loss) income from continuing operations before taxes consisted of the following:
Years Ended December 31,
202320222021
U.S.$(472,848)$(39,294)$(85,258)
International66,346 79,174 77,843 
Total$(406,502)$39,880 $(7,415)

The (benefit) provision for income taxes from continuing operations consisted of the following:
Years Ended December 31,
202320222021
U.S. Federal:
Current$13,722 $223 $(7,419)
Deferred(44,504)(12,284)(13,825)
(30,782)(12,061)(21,244)
U.S. State and Local:
Current5,641 (9,716)5,401 
Deferred(12,189)7,137 (5,827)
(6,548)(2,579)(426)
International:
Current10,577 8,745 10,979 
Deferred5,878 8,835 (231)
16,455 17,580 10,748 
Total current29,940 (748)8,961 
Total deferred(50,815)3,688 (19,883)
Total (benefit) provision for income taxes
$(20,875)$2,940 $(10,922)
Effective tax rate5.1 %7.4 %147.3 %
The effective tax rate for 2023 includes a benefit of $3 million on the aggregate $339 million goodwill impairment charge as the majority of this charge is nondeductible.
The effective tax rate for 2022 includes a tax benefit of $5 million on the pre-tax gain of $5 million from the Borderfree sale as the tax basis was higher than book basis and a $1 million benefit associated with the 2019 sale of a business.

The effective tax rate for 2021 includes benefits of $7 million from the resolution of tax matters, $5 million due to tax legislation in the U.K., $3 million from an affiliate reorganization and $2 million from the vesting of restricted stock, partially offset by charges of $6 million on the pre-tax gain of $10 million from the sale of a business as the tax basis was lower than the book basis and $1 million for the write-off of deferred tax assets associated with the expiration of out-of-the-money stock options.
A reconciliation of income taxes computed at the federal statutory rate and our provision for income taxes consist of the following:
Years Ended December 31,
202320222021
Federal statutory provision$(85,366)$8,375 $(1,558)
State and local income taxes (1)
(5,173)(1,612)(336)
Impact of foreign operations taxed at rates other than the U.S. statutory rate (2)
2,646 3,349 (2,220)
Accrual/release of uncertain tax amounts related to foreign operations(2,829)(2,753)(7,288)
U.S. tax impacts of foreign income in the U.S. (3)
1,099 1,089 4,441 
CARES Act carryback benefit— — (2,270)
Tax credits(1,683)(850)(500)
Unrealized stock compensation benefits574 572 (505)
Goodwill impairment68,557 — — 
Borderfree tax basis differences— (5,610)— 
Other, net (4)
1,300 380 (686)
(Benefit) provision for income taxes
$(20,875)$2,940 $(10,922)
(1)    Includes a benefit of $1 million related to tax resolutions and a benefit of $1 million for tax return true-ups for the year ended December 31, 2022.
(2)    Includes a charge of $2 million for a deferred rate change and a charge of $1 million for the establishment of a valuation allowance for the year ended December 31, 2022 and a benefit of $5 million for a deferred rate change for the year ended December 31, 2021.
(3)    Includes a benefit of $1 million for the year ended December 31, 2022 associated with the sale of a business.
(4)     Includes a $1 million charge associated with nondeductible officer compensation for the year ended December 31, 2023 and a $3 million benefit from an affiliate reorganization and a charge of $3 million related to the sale of a business for the year ended December 31, 2021.
Deferred tax liabilities and assets consisted of the following:
December 31,
20232022
Deferred tax liabilities:
Depreciation$(16,585)$(51,717)
Deferred profit (for tax purposes) on sale to finance subsidiary(43,057)(26,765)
Lease revenue and related depreciation(205,773)(216,282)
Intangible assets(60,420)(65,916)
Operating lease liability(76,910)(73,403)
Basis adjustment in subsidiary
(51,548)— 
Other(19,690)(27,366)
Gross deferred tax liabilities(473,983)(461,449)
Deferred tax assets:
Postretirement medical benefits23,472 24,892 
Pension15,042 9,640 
Operating lease asset83,696 78,765 
Long-term incentives11,814 12,946 
Net operating and capital losses182,482 130,640 
Tax credit carry forwards65,095 66,256 
Section 163j carryforward47,802 23,917 
Tax uncertainties gross-up4,904 4,982 
Other48,537 50,345 
Gross deferred tax assets482,844 402,383 
Less: Valuation allowance(159,342)(157,450)
Net deferred tax assets323,502 244,933 
Total deferred taxes, net$(150,481)$(216,516)
The valuation allowance relates primarily to certain foreign, state and local net operating loss and tax credit carryforwards that will more-likely-than-not expire unutilized.
We have a federal net operating loss carryforward of $3 million as of December 31, 2023, that have a 20 year carryforward period. We have net operating loss carryforwards in international jurisdictions of $390 million as of December 31, 2023, of which $138 million can be carried forward indefinitely and the remainder expire over the next 20 years. We also have net operating loss carryforwards in most states totaling $969 million that will expire over the next 20 years. In addition, we have tax credit carryforwards of $65 million, of which $52 million can be carried forward indefinitely and the remainder expire over the next 10 years.

As of December 31, 2023, we assert that we are permanently reinvested in our pre-1987 and post-2017 undistributed earnings of $365 million as well as all other outside basis differences. While a determination of the full liability that would be incurred if these earnings were repatriated is not practicable, we have estimated the withholding taxes would be approximately $3 million.
Uncertain Tax Positions
A reconciliation of the amount of unrecognized tax benefits is as follows:
202320222021
Balance at beginning of year$33,300 $45,072 $50,064 
Increases from prior period positions343 6 3,016 
Decreases from prior period positions(524)(6,830)(4,247)
Increases from current period positions400 340 492 
Decreases relating to settlements with tax authorities(350)(1,966)(1,270)
Reductions from lapse of applicable statute of limitations(2,937)(3,322)(2,983)
Balance at end of year$30,232 $33,300 $45,072 
The amount of the unrecognized tax benefits at December 31, 2023, 2022 and 2021 that would affect the effective tax rate if recognized was $26 million, $29 million and $39 million, respectively.
On a regular basis, we conclude tax return examinations, statutes of limitations expire, and court decisions interpret tax law. We regularly assess tax uncertainties in light of these developments. As a result, it is reasonably possible that the amount of our unrecognized tax benefits will decrease in the next 12 months, and we expect this change could be up to 15% of our unrecognized tax benefits. We recognize interest and penalties related to uncertain tax positions in our provision for income taxes. Amounts included in our provision for income taxes related to interest and penalties on uncertain tax positions for each of the years ended December 31, 2023, 2022 and 2021 were not significant. We had approximately $4 million and $3 million accrued for the payment of interest and penalties at December 31, 2023 and 2022, respectively.

Other Tax Matters
With regard to U.S. Federal income tax, the Internal Revenue Service examination of our consolidated U.S. income tax returns for tax years prior to 2020 are closed to audit, except for review of the Tax Cuts and Jobs Act (TCJA) Sec 965 transition tax. On a state and local level, returns for most jurisdictions are closed through 2017. For our significant non-U.S. jurisdictions, Canada is closed to examination through 2018 except for a specific issue under current exam, and France, Germany and the U.K. are closed through 2019, 2016, and 2021 respectively. We also have other less significant tax filings currently subject to examination.
We regularly assess the likelihood of tax adjustments in each of the tax jurisdictions in which we have operations and account for the related financial statement implications. We believe we have established tax reserves that are appropriate given the possibility of tax adjustments. However, determining the appropriate level of tax reserves requires judgment regarding the uncertain application of tax law and the possibility of tax adjustments. Future changes in tax reserve requirements could have a material positive or negative impact on our results of operations, financial position and cash flows.