

	Year Ended December 31,
(in millions)	2019		2018			2017
Earnings before income taxes:
U.S.	$	310	$	220		$	203
Non-U.S.	955		976			860
Total	$	1,265	$	1,196		$	1,063
Provision for income taxes:
Current:
Federal	$	32	$	17		$	36
State	4		5			5
Foreign	245		259			247
Total current	281		281			288
Deferred:
Federal	150		(40		)	324
State	23		(8		)	2
Foreign	14		(22		)	(34		)
Total deferred	187		(70		)	292
Total provision for income taxes	$	468	$	211		$	580

The provision for income taxes resulted in an effective tax rate of 37%, 17.7% and 54.7% for the years ended December 31, 2019, 2018 and 2017, respectively. An analysis of the differences between the effective tax rate and the U.S. statutory rate for the years ended December 31, 2019, 2018 and 2017 is presented below.

On December 22, 2017, the Tax Cuts and Jobs Act (the "Tax Act"), was enacted into law, which significantly changed existing U.S. tax law and included many provisions applicable to the Company, such as reducing the U.S. federal statutory tax rate, imposing a one-time transition tax on deemed repatriation of deferred foreign income, and adopting a territorial tax system. The Tax Act reduced the U.S. federal statutory tax rate from 35% to 21% effective January 1, 2018. The Tax Act also includes a provision to tax Global Intangible Low-Taxed Income (“GILTI”) of foreign subsidiaries, a special tax deduction for Foreign-Derived Intangible Income (“FDII”), and a Base Erosion Anti-Abuse (“BEAT”) tax measure that may tax certain payments between a U.S. corporation and its subsidiaries. These additional provisions of the Tax Act were effective beginning January 1, 2018.

In accordance with guidance provided by Staff Accounting Bulletin No 118 (SAB 118), as of December 31, 2017, the Company had not completed its accounting for the tax effects of the Tax Act and had recorded provisional estimates for significant items including the following: (i) the effects on existing deferred balances, including executive compensation, (ii) the one-time transition tax, and (iii) its indefinite reinvestment assertion. In light of the treatment of foreign earnings under the Tax Act, the Company reconsidered its indefinite reinvestment position and concluded it would no longer assert indefinite reinvestment with respect to the Company's foreign unremitted earnings as of December 31, 2017. The Company recognized income tax expense of $274 million for the year ended December 31, 2017 for the significant items it could reasonably estimate associated with the Tax Act. This amount was comprised of (i) a revaluation of U.S. deferred tax assets and liabilities at December 31, 2017, resulting in a tax charge of $75 million, including $11 million for executive compensation (ii) a one-time transition tax resulting in a tax charge of $105 million and (iii) a tax charge of $94 million for additional provisional deferred tax liabilities with respect to the expected future remittance of foreign earnings.

For the year ended December 31, 2018, the Company completed its accounting for the tax effects of the Tax Act. The final SAB 118 adjustments resulted in: (i) an increase in the Company's existing deferred tax asset balances of $13 million, including $9 million for executive compensation (ii) a tax charge of $8 million for the one-time transition tax, and (iii) a decrease in the deferred tax liability associated with its indefinite reinvestment assertion of $7 million. The total impact to tax expense from these adjustments was a net tax benefit of $13 million. Compared to the year ended December 31, 2017, this additional tax benefit from the final adjustments was a result of further analysis performed by the Company and the issuance of additional regulatory guidance.

As discussed above, in light of the treatment of foreign earnings under the Tax Act, the Company reconsidered its indefinite reinvestment position with respect to its foreign unremitted earnings in 2017, and the Company is no longer asserting indefinite reinvestment with respect to its foreign unremitted earnings. The Company recorded a deferred tax liability of $56 million with respect to its foreign unremitted earnings at December 31, 2019. With respect to certain book versus tax basis differences not represented by undistributed earnings of approximately $400 million as of December 31, 2019, the Company continues to assert indefinite reinvestment of these basis differences. These basis differences would become taxable upon the sale or liquidation of the foreign subsidiaries. The Company's best estimate of the unrecognized deferred tax liability on these basis differences is approximately $20 million as of December 31, 2019.



	Year Ended December 31,
(in millions)	2019			2018			2017
Income taxes at U.S. statutory rate of 21% for 2019 and 2018 (35% for 2017)	$	266		$	251		$	372
Increases (decreases) resulting from:
Impact of transactions	124			(1		)	4
Reserve adjustments, settlements and claims	46			32			8
Foreign rate differentials	35			28			(100		)
Net tax on remittance of foreign earnings	22			(22		)	80
U.S. tax on non-U.S. earnings	15			37			171
Other foreign taxes	10			8			8
State taxes, net of federal benefit	3			6			2
Non-deductible transaction costs	3			3			11
Impact of foreign derived intangible income	(1		)	(15		)	—
Valuation allowance adjustments	(2		)	(11		)	12
Affiliates' earnings	(7		)	(10		)	(18		)
Changes in accounting methods and filing positions	(7		)	(30		)	(2		)
Tax credits	(17		)	(26		)	(24		)
Tax holidays	(26		)	(28		)	(31		)
Revaluation of U.S. deferred taxes	—			(4		)	64
Other	4			(7		)	23
Provision for income taxes, as reported	$	468		$	211		$	580

an increase in income tax expense of $173 million for the reversal of the asbestos-related deferred tax assets. This amount is offset in the rate reconciliation above by a benefit of $37 million representing the impact of the nontaxable pre-tax gain of $177 million.The items related to the Tax Act include an increase in tax expense of $22 million due to the U.S. Department of the Treasury’s issuance of the final regulations in the first quarter of 2019 related to the calculation of the one-time transition tax. Additionally, the Company recorded a tax expense of $22 million on net remittance of foreign earnings in 2019 compared to a tax benefit recorded in 2018. The tax benefit in 2018 is related to the refinement in the Company’s change in the indefinite reinvestment assertion.

The Company's provision for income taxes for the year ended December 31, 2019 includes an increase in income tax expense for the items mentioned above. In addition, the provision for income taxes also includes reductions of income tax expense of $19 million related to restructuring and merger, acquisition and divestiture expense, $11 million for a global realignment plan, $8 million related to other one-time adjustments and $6 million related to pension settlement loss.

The change in the effective tax rate for 2018, as compared to 2017, was primarily due to items related to the Tax Act. The Tax Act includes a reduction in the US income tax rate from 35% to 21%, as of January 1, 2018. Tax expense includes a provision for GILTI of $29 million, net of foreign tax credits and a tax benefit for FDII of $15 million that was not applicable in 2017. The one-time transition tax that resulted in a tax charge of $105 million in 2017 was not applicable in 2018. There was also a tax charge of $75 million related to a revaluation of U.S. deferred tax assets and liabilities, including $11 million for executive compensation in 2017 and the initial tax charge of $94 million related to the Company’s change in indefinite reinvestment assertion with respect to the expected future remittance of undistributed foreign earnings in 2017.

The Company's provision for income taxes for the year ended December 31, 2018 includes reductions of income tax expense of $15 million related to restructuring expense, $6 million related to the asbestos-related adjustments, and $8 million related to asset impairment expense, offset by increases to tax expense of $1 million and $6 million related to a gain on commercial settlement and a gain on the sale of a building, respectively, discussed in Note 4, "Other (Income) Expense, Net," to the Consolidated Financial Statements. The provision for income taxes also includes reductions of income tax expense of $13 million related to final adjustments made to measurement period provisional estimates associated with the Tax Act, $22 million related to a decrease in the Company's deferred tax liability due to a tax benefit for certain foreign tax credits now available due to actions the Company took during the year, $9 million related to valuation allowance releases, $3 million related to tax reserve adjustments, and $30 million related to changes in accounting methods and tax filing positions for prior years primarily related to the Tax Act.

The Company's provision for income taxes for the year ended December 31, 2017 includes reductions of income tax expense of $10 million, $1 million, $18 million and $4 million related to the restructuring expense, merger and acquisition expense, asset impairment expense and other one-time adjustments, respectively, discussed in Note 4, "Other (Income) Expense, Net," to the Consolidated Financial Statements.



(in millions)	2019			2018			2017
Balance, January 1	$	120		$	92		$	91
Additions based on tax positions related to current year	7			24			17
Additions/(reductions) for tax positions of prior years	26			18			(2		)
Reductions for closure of tax audits and settlements	—			(8		)	(20		)
Reductions for lapse in statute of limitations	(6		)	—			(1		)
Translation adjustment	(1		)	(6		)	7
Balance, December 31	$	146		$	120		$	92

The Company recognizes interest and penalties related to unrecognized tax benefits in income tax expense. The amounts recognized in income tax expense for 2019 and 2018 are $15 million and $10 million, respectively. The Company has an accrual of approximately $46 million and $32 million for the payment of interest and penalties at December 31, 2019 and 2018, respectively. As of December 31, 2019, approximately $144 million represents the amount that, if recognized, would affect the Company's effective income tax rate in future periods. This amount includes a decrease in U.S. federal income taxes that would occur upon recognition of the state tax benefits and U.S. foreign tax credits included therein. The Company estimates that approximately $5 million will be released in the next 12 months for the closure of an audit and the lapse in statute of limitations subsequent to the reporting period from certain taxing jurisdictions.

The Company and/or one of its subsidiaries files income tax returns in the U.S. federal, various state jurisdictions and various foreign jurisdictions. In certain tax jurisdictions, the Company may have more than one taxpayer. The Company is no longer subject to income tax examinations by tax authorities in its major tax jurisdictions as follows:



Tax jurisdiction	Years no longer subject to audit	Tax jurisdiction	Years no longer subject to audit
U.S. Federal	2014 and prior	Japan	2018 and prior
China	2012 and prior	Mexico	2013 and prior
France	2015 and prior	Poland	2013 and prior
Germany	2011 and prior	South Korea	2013 and prior
Hungary	2013 and prior

In the U.S., certain tax attributes created in years prior to 2015 were subsequently utilized. Even though the U.S. federal statute of limitations has expired for years prior to 2015, the years in which these tax attributes were created could still be subject to examination, limited to only the examination of the creation of the tax attribute.



	December 31,
(in millions)	2019			2018
Deferred tax assets:
Research and development capitalization	$	74		$	92
Net operating loss and capital loss carryforwards	70			84
Other comprehensive loss	53			64
Unrecognized tax benefits	49			41
Employee compensation	32			24
Pension and other postretirement benefits	25			19
State tax credits	21			20
Warranty	15			14
Foreign tax credits	13			—
Asbestos-related	—			172
Other	67			80
Total deferred tax assets	$	419		$	610
Valuation allowance	(71		)	(86		)
Net deferred tax asset	$	348		$	524
Deferred tax liabilities:
Goodwill and intangible assets	(174		)	(183		)
Fixed assets	(144		)	(118		)
Unremitted foreign earnings	(56		)	(57		)
Other	(20		)	(19		)
Total deferred tax liabilities	$	(394	)	$	(377	)
Net deferred taxes	$	(46	)	$	147

At December 31, 2019, certain non-U.S. subsidiaries have net operating loss carryforwards totaling $212 million available to offset future taxable income. Of the total $212 million, $147 million expire at various dates from 2020 through 2039 and the remaining $65 million have no expiration date. The Company has a valuation allowance recorded against $134 million of the $212 million of non-U.S. net operating loss carryforwards. The Company has a U.S. foreign tax credit carryover of $13 million, which is partially offset by a valuation allowance of $2 million. Certain U.S. subsidiaries have state net operating loss carryforwards totaling $571 million, which are largely offset by a valuation allowance of $504 million. The state net operating loss carryforwards expire at various dates from 2020 to 2039. Certain U.S. subsidiaries also have state tax credit carryforwards of $21 million which are partially offset by a valuation allowance of $19 million. Certain non-U.S. subsidiaries located in China had tax exemptions or tax holidays, which reduced local tax expense approximately $26 million and $28 million in 2019 and 2018, respectively. The tax holidays for these subsidiaries are issued in three-year terms with expirations for certain subsidiaries ranging from 2019 to 2021.