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INCOME TAXES (Tables)

12 Months Ended

Dec. 31, 2021

Components of loss before benefit from income taxes

The components of Loss before benefit from income taxes for 2021, 2020 and 2019 consist of:


(in millions)	2021		2020		2019
Domestic	$	(323)	$	(410)	$	(2,396)
Foreign	(701)		(524)		559
	$	(1,024)	$	(934)	$	(1,837)

Components of benefit from income taxes

The components of Benefit from income taxes for 2021, 2020 and 2019 consist of:


(in millions)	2021		2020		2019
Current:
Domestic	$	(23)	$	(8)	$	(12)
Foreign	74		(216)		(116)
	51		(224)		(128)
Deferred:
Domestic	20		9		(5)
Foreign	16		590		187
	36		599		182
	$	87	$	375	$	54

Reconciliation of benefit from income taxes from the expected amount calculated by applying the Canadian statutory rate to loss before benefit of income taxes

The Benefit from income taxes differs from the expected amount calculated by applying the Company’s Canadian statutory rate of 26.9% to Loss before benefit from income taxes for 2021, 2020 and 2019 as follows:


(in millions)	2021		2020		2019
Loss before benefit from income taxes	$	(1,024)	$	(934)	$	(1,837)
Benefit from income taxes
Expected benefit from income taxes at Canadian statutory rate	$	275	$	251	$	494
Non-deductible amount of share-based compensation	(9)		(9)		(7)
Adjustments to tax attributes	(59)		26		(99)
Change in valuation allowance related to foreign tax credits and NOLs	28		62		21
Change in valuation allowance on Canadian deferred tax assets and tax rate changes	40		687		(142)
Change in uncertain tax positions	112		(163)		(350)
Foreign tax rate differences	(198)		(128)		186
Non-deductible portion of Goodwill impairments	(99)		—		—
Tax benefit on intra-entity transfers	—		(338)		—
Other	(3)		(13)		(49)
	$	87	$	375	$	54

Schedule of tax effect of major items recorded as deferred tax assets and liabilities and valuation allowance

Deferred tax assets and liabilities as of December 31, 2021 and 2020 consist of:


(in millions)	2021		2020
Deferred tax assets:
Tax loss carryforwards	$	2,973	$	2,924
Provisions	991		1,004
Research and development tax credits	173		172
Scientific Research and Experimental Development pool	52		55
Tax credit carryforwards	14		20
Deferred revenue	3		9
Prepaid expenses	26		27
Share-based compensation	17		16
Other	38		24
Total deferred tax assets	4,287		4,251
Less valuation allowance	(2,222)		(2,252)
Deferred tax assets net of valuation allowance	2,065		1,999
Deferred tax liabilities:
Intangible assets	188		228
Plant, equipment and technology	44		89
Outside basis differences	110		71
Unrealized FX on U.S. dollar debt and other financing cost	—		2
Total deferred tax liabilities	342		390
Net deferred tax asset	$	1,723	$	1,609

The following table presents a reconciliation of the deferred tax asset valuation allowance for 2021, 2020 and 2019:


(in millions)	2021		2020		2019
Balance, beginning of year	$	2,252	$	2,831	$	2,913
Charged to Benefit from income taxes	(63)		(773)		13
Charged to other accounts	33		194		(95)
Balance, end of year	$	2,222	$	2,252	$	2,831

Summary of open tax years by jurisdiction


Jurisdiction:						Open Years
United States - Federal						2015 - 2020
Canada						2012 - 2020
Germany						2014 - 2020
France						2013 - 2020
China						2016 - 2020
Ireland						2016 - 2020
Netherlands						2017 - 2020
Australia						2011 - 2020
Luxembourg						2017 - 2020

Reconciliation of the beginning and ending amounts of unrecognized tax benefits

The following table presents a reconciliation of the unrecognized tax benefits for 2021, 2020 and 2019:


(in millions)	2021		2020		2019
Balance, beginning of year	$	1,025	$	1,002	$	654
Additions based on tax positions related to the current year	79		66		361
Additions for tax positions of prior years	121		171		63
Reductions for tax positions of prior years	(129)		(209)		(58)
Lapse of statute of limitations	(169)		(5)		(18)
Balance, end of year	$	927	$	1,025	$	1,002