The U.S. and International components of loss before income taxes consisted of the following for the years ended, December 31:

In millions
	2019			2018			2017
United States	$	(150.5	)	$	(189.1	)	$	(9.6	)
Foreign		(212.3	)		(86.3	)		(98.3	)
Total loss before income taxes	$	(362.8	)	$	(275.4	)	$	(107.9	)

Significant components of the Company’s income tax benefit (expense) for the years ended December 31, are as follows:

In millions
	2019			2018			2017
Current
United States - federal	$	-		$	-		$	(107.0	)
United States - state and local		(10.7	)		(0.4	)		(10.0	)
Foreign		(6.4	)		(8.5	)		(7.1	)
		(17.1	)		(8.9	)		(124.1	)
Deferred
United States - federal		23.9			24.4			256.1
United States - state and local		8.0			11.2			9.8
Foreign		2.0			3.1			9.1
		33.9			38.7			275.0
Total benefit	$	16.8		$	29.8		$	150.9

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

	2019			2018			2017
Federal statutory income tax rate		21.0	%		21.0	%		35.0	%
Effect of:
State and local taxes, net of federal tax effect		1.2	%		4.2	%		3.9	%
Foreign tax rates		5.1	%		4.2	%		(2.7	%)
Permanent - other items		(4.2	%)		0.5	%		(2.1	%)
Permanent - goodwill impairment		(14.1	%)		(9.1	%)		(12.0	%)
Tax Act		-			(3.2	%)		120.3	%
Valuation allowance		(1.2	%)		(7.5	%)		(4.6	%)
Divestitures		1.2	%		-			-
Stock-based compensation		(1.0	%)		1.2	%		(0.6	%)
Other		(3.4	%)		(0.5	%)		2.7	%
Effective tax rate		4.6	%		10.8	%		139.9	%

In millions
	2019			2018
Deferred tax liabilities:
Property, plant and equipment	$	(68.1	)	$	(68.9	)
Goodwill and intangibles		(417.9	)		(395.1	)
Leases - right of use asset		(84.5	)		-
Other		(10.9	)		(22.7	)
Total deferred tax liabilities		(581.4	)		(486.7	)
Deferred tax assets:
Accrued liabilities		87.8			84.4
Leases - right of use liability		88.7			-
Net operating tax loss carry-forwards		116.2			88.9
Interest expense carry-forward		31.2			13.4
Other		11.4			39.9
Less: valuation allowance		(39.4	)		(35.3	)
Total deferred tax assets		295.9			191.3
Net deferred tax liabilities	$	(285.5	)	$	(295.4	)

The valuation allowance increased $4.1 million during the year ended December 31, 2019, primarily due to non-benefited foreign losses.

On December 22, 2017, the Tax Act was signed into law making significant changes to the Internal Revenue Code. Changes included, but were 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.

In accordance with SAB 118 and the Company’s 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, the Company 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, the accounting for the various elements of the Tax Act was 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.

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 for investments in its 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 outstanding basis difference is not practicable to calculate.

At December 31, 2019, the net operating loss carry-forwards from both foreign and domestic operations are approximately $379.4 million and certain of these net operating loss carry-forwards begin to expire in 2021. The tax benefit of these net operating losses is approximately $116.2 million at December 31, 2019, on which a valuation allowance of $30.8 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 2015.

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, 2019 is $62.7 million. The amount of uncertain tax positions that, if recognized, would affect the effective tax rate is approximately $61.3

million. We recognized interest and penalties related to income tax reserves in the amount of $(0.7) million, $0.8 million, and $0.3 million for the years ended December 31, 2019, 2018 and 2017, 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, 2019 and 2018:

In millions
Unrecognized tax positions as of January 1, 2018	$	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
Gross increases (decreases) - tax positions in prior periods		1.2
Gross increases - current period tax positions		4.6
Settlement		(0.2	)
Lapse of statute of limitations		(7.6	)
Unrecognized tax positions as of December 31, 2019	$	62.7

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 filed a PFA with the IRS related to a claim under Internal Revenue Code Section 1341 concerning the tax rate to be applied to the SQ Settlement on the Company’s 2018 tax return. The IRS has agreed to review the position and discussions are ongoing.

As of December 31, 2019 and 2018, the Company has established a long-term receivable and an amount within the uncertain tax positions to reflect its estimate of the potential refund should its claim be successful. Any positive income tax benefit resulting from the claim in a future period will be recognized as appropriate in accordance with the guidance in ASC 740 on the accounting for uncertain tax positions. There can be no assurance that this amount or any amount will be recovered as a result of this claim.