INCOME TAXES

U.S. and foreign earnings from continuing operations before income taxes are as follows:



	Years Ended December 31,
	2015		2014		2013
	(In thousands)
U.S.	$	79,639	$	174,792	$	331,520
Foreign	63,234		95,137		84,781
Total	$	142,873	$	269,929	$	416,301

The components of the provision (benefit) for income taxes attributable to continuing operations are as follows:



	Years Ended December 31,
	2015			2014			2013
	(In thousands)
Current income tax provision (benefit):
Federal	$	67,505		$	(45,842	)	$	115,250
State	7,785			(14,787		)	13,946
Foreign	14,012			19,132			14,402
Current income tax provision (benefit)	89,302			(41,497		)	143,598
Deferred income tax (benefit) provision:
Federal	(50,254		)	74,255			(821		)
State	(3,727		)	3,090			(2,117		)
Foreign	(5,805		)	(476		)	(6,158		)
Deferred income tax (benefit) provision	(59,786		)	76,869			(9,096		)
Income tax provision	$	29,516		$	35,372		$	134,502

The current income tax payable was reduced by $56.4 million, $45.0 million and $32.9 million for the years ended December 31, 2015, 2014 and 2013, respectively, for excess tax deductions attributable to stock-based compensation. The related income tax benefits are recorded as increases to additional paid-in capital.

Income taxes receivable (payable) and deferred tax assets (liabilities) are included in the following captions in the accompanying consolidated balance sheet at December 31, 2015 and 2014:



	December 31,
	2015			2014
	(In thousands)
Income taxes receivable (payable):
Other current assets	$	26,793		$	4,505
Other non-current assets	1,564			1,478
Accrued expenses and other current liabilities	(33,029		)	(41,157		)
Income taxes payable	(33,692		)	(32,635		)
Net income taxes payable	$	(38,364	)	$	(67,809	)

Deferred tax assets (liabilities):
Other non-current assets	$	1,970		$	1,379
Deferred income taxes	(348,773		)	(391,790		)
Net deferred tax liabilities	$	(346,803	)	$	(390,411	)

The tax effects of cumulative temporary differences that give rise to significant deferred tax assets and deferred tax liabilities are presented below. The valuation allowance relates to deferred tax assets for which it is more likely than not that the tax benefit will not be realized.



	December 31,
	2015			2014
	(In thousands)
Deferred tax assets:
Accrued expenses	$	36,418		$	34,654
Net operating loss carryforwards	68,048			55,579
Tax credit carryforwards	13,753			13,585
Stock-based compensation	76,285			69,342
Cost method investments	6,251			27,581
Equity method investments	17,105			14,998
Other	16,057			12,322
Total deferred tax assets	233,917			228,061
Less valuation allowance	(90,482		)	(98,350		)
Net deferred tax assets	143,435			129,711
Deferred tax liabilities:
Investment in subsidiaries	(382,254		)	(378,769		)
Intangible and other assets	(88,846		)	(115,470		)
Other	(19,138		)	(25,883		)
Total deferred tax liabilities	(490,238		)	(520,122		)
Net deferred tax liabilities	$	(346,803	)	$	(390,411	)

At December 31, 2015, the Company has federal and state net operating losses ("NOLs") of $74.3 million and $96.1 million, respectively. If not utilized, the federal NOLs will primarily expire at various times between 2030 and 2035, and the state NOLs will expire at various times between 2016 and 2035. Utilization of federal and state NOLs will be subject to limitations under Section 382 of the Internal Revenue Code and applicable state law. At December 31, 2015, the Company has foreign NOLs of $132.3 million available to offset future income. Of these foreign NOLs, $115.7 million can be carried forward indefinitely and $16.6 million will expire at various times between 2015 and 2035. During 2015, the Company recognized tax benefits related to NOLs of $2.7 million. At December 31, 2015, the Company has federal and state capital losses of $2.2 million and $20.8 million, respectively. If not utilized, the capital losses will expire between 2016 and 2020. Utilization of capital losses will be limited to the Company's ability to generate future capital gains.

At December 31, 2015, the Company has tax credit carryforwards of $18.5 million. Of this amount, $6.6 million relates to state tax credits for research activities, $6.2 million relates to federal credits for foreign taxes, and $5.7 million relates to various state and local tax credits. Of these credit carryforwards, $8.6 million can be carried forward indefinitely and $9.9 million will expire within ten years.

During 2015, the Company's valuation allowance decreased by $7.9 million primarily due to the realization of certain deferred tax assets, partially offset by an increase in unrealized net operating and capital losses. At December 31, 2015, the Company has a valuation allowance of $90.5 million related to the portion of tax loss carryforwards and other items for which it is more likely than not that the tax benefit will not be realized.

A reconciliation of the income tax provision to the amounts computed by applying the statutory federal income tax rate to earnings from continuing operations before income taxes is shown as follows:



	Years Ended December 31,
	2015			2014			2013
	(In thousands)
Income tax provision at the federal statutory rate of 35%	$	50,006		$	94,475		$	145,705
Change in tax reserves, net	(2,928		)	(86,151		)	1,791
Foreign income taxed at a different statutory tax rate	(6,077		)	(10,456		)	(17,428		)
State income taxes, net of effect of federal tax benefit	2,208			7,240			7,668
Realization of certain deferred tax assets	(22,440		)	—			(6,026		)
Non-taxable contingent consideration fair value adjustments	(4,517		)	(4,439		)	120
Non-taxable foreign currency exchange gains	(4,306		)	—			—
Unbenefited losses	4,264			5,433			3,350
Non-deductible goodwill associated with the sale of Urbanspoon	—			6,982			—
Non-deductible ShoeBuy goodwill impairment	4,920			—			—
Non-deductible impairments for certain cost method investments	2,341			23,310			1,756
Other, net	6,045			(1,022		)	(2,434		)
Income tax provision	$	29,516		$	35,372		$	134,502

No income taxes have been provided on indefinitely reinvested earnings of certain foreign subsidiaries aggregating $555.9 million at December 31, 2015. The estimated amount of the unrecognized deferred income tax liability with respect to such earnings is $127.2 million.

A reconciliation of the beginning and ending amount of unrecognized tax benefits, excluding interest, is as follows:



	December 31,
	2015			2014			2013
	(In thousands)
Balance at January 1	$	30,386		$	275,813		$	379,281
Additions based on tax positions related to the current year	4,227			2,159			2,887
Additions for tax positions of prior years	14,467			1,622			3,189
Reductions for tax positions of prior years	(1,556		)	(5,611		)	(17,116		)
Settlements	—			(5,092		)	(78,954		)
Expiration of applicable statutes of limitations	(6,716		)	(238,505		)	(13,474		)
Balance at December 31	$	40,808		$	30,386		$	275,813

The Company recognizes interest and, if applicable, penalties related to unrecognized tax benefits in the income tax provision. Included in the income tax provision for continuing operations for the years ended December 31, 2015, 2014 and 2013 is a $0.1 million expense, $58.5 million benefit and $4.8 million expense, respectively, net of related deferred taxes of less than $0.1 million, $35.3 million and $2.8 million, respectively, for interest on unrecognized tax benefits. Included in the income tax provision for discontinued operations for the years ended December 31, 2015, 2014 and 2013 is a less than $0.1 million benefit, $19.7 million benefit and $1.4 million expense, respectively, net of related deferred taxes of less than $0.1 million, $11.7 million and $0.8 million, respectively, for interest on unrecognized tax benefits. At December 31, 2015 and 2014, the Company has accrued $2.5 million and $2.8 million, respectively, for the payment of interest. At December 31, 2015 and 2014, the Company has accrued $2.2 million and $2.9 million, respectively, for penalties.

The Company is routinely under audit by federal, state, local and foreign authorities in the area of income tax. These audits include questioning the timing and the amount of income and deductions and the allocation of income and deductions among various tax jurisdictions. The Internal Revenue Service is currently auditing the Company’s federal income tax returns for the years ended December 31, 2010 through 2012. Various other jurisdictions are open to examination for various tax years beginning with 2009. Income taxes payable include reserves considered sufficient to pay assessments that may result from examination of prior year tax returns. Changes to reserves from period to period and differences between amounts paid, if any, upon resolution of audits and amounts previously provided may be material. Differences between the reserves for income tax contingencies and the amounts owed by the Company are recorded in the period they become known.

At December 31, 2015 and 2014, unrecognized tax benefits, including interest, were $43.4 million and $33.2 million, respectively. If unrecognized tax benefits at December 31, 2015 are subsequently recognized, $41.0 million, net of related deferred tax assets and interest, would reduce income tax expense. The comparable amount as of December 31, 2014 was $30.5 million. The Company believes that it is reasonably possible that its unrecognized tax benefits could decrease by approximately $8.1 million by December 31, 2016, primarily due to expirations of statutes of limitations; $7.7 million of which would reduce the income tax provision for continuing operations.