The U.S. and International components of (loss) income before income taxes (benefit) expense consisted of the following for the years ended December 31, 2018, 2017, and 2016:

In millions
	2018			2017			2016
United States	$	(189.1	)	$	(9.6	)	$	381.1
Foreign		(86.3	)		(98.3	)		(53.0	)
Total (loss) income before income taxes	$	(275.4	)	$	(107.9	)	$	328.1

Significant components of our income tax benefit (expense) for the years ended December 31, 2018, 2017, and 2016 are as follows:

In millions
	2018			2017			2016
Current
United States – federal	$	-		$	(107.0	)	$	(102.0	)
United States - state and local		(0.4	)		(10.0	)		(11.6	)
Foreign		(8.5	)		(7.1	)		(10.6	)
		(8.9	)		(124.1	)		(124.2	)
Deferred
United States – federal		24.4			256.1			(19.1	)
United States - state and local		11.2			9.8			2.5
Foreign		3.1			9.1			20.6
		38.7			275.0			4.0
Total benefit (expense)	$	29.8		$	150.9		$	(120.2	)

A reconciliation of the income tax provision computed at the federal statutory rate to the effective tax rate for the years ended December 31, 2018, 2017, and 2016 are as follows:

	2018			2017			2016
Federal statutory income tax rate		21.0	%		35.0	%		35.0	%
Effect of:
State and local taxes, net of federal tax effect		4.2	%		3.9	%		1.5	%
Foreign tax rates		4.2	%		(2.7	%)		2.1	%
Permanent - other items		0.5	%		(2.1	%)		0.8	%
Permanent - goodwill impairment		(9.1	%)		(12.0	%)		-
U.S. Tax Reform Act		(3.2	%)		120.3	%		-
Valuation allowance		(7.5	%)		(4.6	%)		2.1	%
Stock-based compensation		1.2	%		(0.6	%)		(1.8	%)
Other		(0.5	%)		2.7	%		(3.1	%)
Effective tax rate		10.8	%		139.9	%		36.6	%

Our deferred tax liabilities and assets at December 31, 2018 and 2017 were as follows:

In millions
	2018			2017
Deferred tax liabilities:
Property, plant and equipment	$	(68.9	)	$	(56.4	)
Goodwill and intangibles		(395.1	)		(490.0	)
Other		(22.7	)		(17.2	)
Total deferred tax liabilities		(486.7	)		(563.6	)
Deferred tax assets:
Accrued liabilities		84.4			141.2
Net operating tax loss carry-forwards		88.9			38.3
Sec 163j carry-forward		13.4			-
Other		39.9			38.6
Less: valuation allowance		(35.3	)		(16.1	)
Total deferred tax assets		191.3			202.0
Net deferred tax liabilities	$	(295.4	)	$	(361.6	)

On December 22, 2017, the U.S. Tax Cuts and Jobs Act of 2017 (the “Tax Act”) was signed into law making significant changes to the Internal Revenue Code. Changes include, but are not limited to, a corporate income tax rate decrease from 35% to 21% effective for tax years beginning after December 31, 2017, the transition of U.S. international taxation from a worldwide tax system to a territorial system, and a one-time transition tax on the mandatory deemed repatriation of cumulative foreign earnings as of December 31, 2017. The Tax Act results in a related change in assertion on expected foreign withholding taxes.

In accordance with SAB 118 and our understanding of the Tax Act and guidance available, the Company calculated the provisional estimate of the tax impact of the Tax Act on its year end 2017 income tax benefit/provision and as a result recognized an income tax (benefit) of ($129.8) million in the fourth quarter of 2017, the period in which the legislation was enacted. The provisional amount related to the re-measurement of certain deferred tax assets and liabilities based on the rates at which they are expected to reverse in the future, the one-time transition tax on the mandatory deemed repatriation of foreign earnings and the related expected foreign withholding taxes on such earnings are reflected in the table below.

The net tax benefit recognized during the year ended December 31, 2017, related to the Tax Act was as follows:

During the year ended December 31, 2018, we adjusted the provisional amounts recognized as of December 31, 2017 for the one-time transition tax, deferred taxes and foreign withholding taxes. These adjustments resulted in a net charge to the tax provision of $8.8 million. As of December 31, 2018, our accounting for the various elements of the Tax Act is complete. Adjustments may be necessary in future periods due to potential technical corrections to the Tax Act and/or regulatory guidance that may be issued by the U.S. Internal Revenue Service.

Beginning in fiscal 2019, the Tax Act also establishes a provision known as global intangible low-taxed income ("GILTI") that imposes a tax on certain earnings of foreign subsidiaries. The Company has made an accounting policy election to treat GILTI taxes as a current period expense.

Prior to the enactment of the Tax Act, the Company treated the undistributed earnings from foreign subsidiaries as indefinitely reinvested. The Company continues to assert permanent reinvestment in its first tier subsidiaries, but lifts the assertion on deferred foreign earnings that were taxed under the Tax Act on lower tier subsidiaries. A withholding tax accrual has been recorded where appropriate. The Company has not provided for deferred taxes on outside basis differences in our investments in our foreign subsidiaries that are unrelated to unremitted earnings as these basis differences will be indefinitely reinvested. A determination of the unrecognized deferred taxes related to these other components of our outstanding basis difference is not practicable to calculate.

At December 31, 2018, the net operating loss carry-forwards from both foreign and domestic operations are approximately $350.3 million and certain of these net operating loss carry-forwards began to expire in 2021. The tax benefit of these net operating losses is approximately $88.9 million at December 31, 2018, on which a valuation allowance of $24.9 million was recognized offsetting such tax benefit.

We file income tax returns in the United States, in various states and in certain foreign jurisdictions.

With a few exceptions, we are no longer subject to U.S. federal, state, local, or non-US income tax examinations by tax authorities for years prior to 2012. The U.S. Internal Revenue Service has completed its audit of our 2014 corporate income tax return and made no changes to our reported tax.

The Company has recognized liabilities to cover certain uncertain tax positions. Such uncertain tax positions relate to additional taxes that the Company may be required to pay in various tax jurisdictions. During the course of examinations by various taxing authorities, proposed adjustments may be asserted. The Company evaluates such items on a case-by-case basis and adjusts the accrual for uncertain tax positions as deemed necessary. The estimated amount of the liability associated with the Company’s uncertain tax positions that may significantly increase or decrease within the next twelve months cannot be reasonably estimated.

The total amount of unrecognized tax benefit at December 31, 2018 is $64.7 million. The amount of uncertain tax positions that, if recognized, would affect the effective tax rate is approximately $61.8 million. We recognized interest and penalties related to income tax reserves in the amount of $0.8 million, $0.3 million, and $1.3 million for the years ended December 31, 2018, 2017, and 2016, respectively, as a component of income tax expense.

The following table summarizes the aggregate changes in unrecognized tax benefits during the years ended December 31, 2018 and 2017:

In millions
Unrecognized tax positions as of January 1, 2017	$	26.7
Gross increases - tax positions in prior periods		0.7
Gross increases - current period tax positions		5.1
Settlement		(0.5	)
Lapse of statute of limitations		(4.6	)
Unrecognized tax positions as of December 31, 2017		27.4
Gross increases - tax positions in prior periods		1.1
Gross increases - current period tax positions		43.5
Settlement		(2.0	)
Lapse of statute of limitations		(5.3	)
Unrecognized tax positions as of December 31, 2018	$	64.7

The table above includes amounts that relate to uncertain tax positions from acquired companies. Purchase agreements to acquire the stock of a target generally provide that the seller is liable for and has indemnified the Company against all income tax liabilities for periods prior to the acquisition. The Company will be responsible for unrecognized tax benefits and related interest and penalties for periods after the acquisition.

The Company is considering a claim under Internal Revenue Code Section 1341 concerning the tax rate to be applied to the small quantity customer class action settlement on the Company’s 2018 tax return. The Company may request a pre-filing agreement (“PFA”) with the U.S. Internal Revenue Service related to the treatment of this item. Once the PFA is settled any positive income tax benefit resulting from the PFA will be recognized at that time.

The Company has established a long term receivable and an amount within the unrecognized tax positons above to reflect its estimate of the potential refund should its claim be successful. There can be no assurance that this amount or any amount will be recovered as a result of this claim.