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Income taxes
 12 Months Ended
Dec. 31, 2023
Income Tax Disclosure [Abstract]  
Income taxes
15. Income taxes
The summary of the Income from continuing operations before income tax expense for the years ended December 31 was:

in $ millions202320222021
Income
U.S.2,7292,2251,596
Non-U.S.1,2851,2361,506
Total income4,0143,4613,102

The summary of the Income tax expense from continuing operations for the years ended December 31 was:

in $ millions202320222021
Current tax:
U.S. - Federal632443304
U.S. - State678747
Non-U.S.290221205
Total current tax expense989751556
Deferred tax:
U.S. - Federal(28)1154
U.S. - State(12)(6)11
Non-U.S.(24)629
Total deferred tax (benefit) expense(64)1194
Total income tax expense925762650

While the Company is domiciled in Ireland, due to the percentage of global operations subject to tax in the United States, the Company uses the U.S. Federal statutory tax rate in the reconciliation of the effective income tax rate. The reconciliation of the applicable U.S. Federal income tax rate to the effective income tax rates was:

in $ millions202320222021
U.S. statutory rate843727651
State tax, net of federal tax benefit387361
Tax rate differentials(11)(6)4
Uncertain tax positions876075
Tax credits(125)(96)(107)
Non-deductible goodwill impairment75––
Other184(34)
Total tax expense925762650
Effective income tax rate23 %22 %21 %
The significant components of the deferred tax assets and liabilities at December 31 were:

in $ millions20232022
Deferred tax assets:
Company retirement benefit plans3826
Revaluation of derivative financial instruments to fair value2–
Tax losses, credits and interest deduction carryforwards1,052855
Share-based compensation4131
Accrued expenses420350
Lease liabilities292263
Total deferred tax assets1,8451,525
Less: valuation allowances(914)(737)
Total deferred tax assets after valuation allowances931788
Deferred tax liabilities:
Investment in subsidiaries155159
Depreciation, depletion and amortization3,1093,165
Leased right-of-use assets274250
Rolled-over capital gains2120
Other12–
Total deferred tax liabilities3,5713,594
Total net deferred tax liabilities2,6402,806

The net deferred tax assets and liabilities that are included in the Consolidated Balance Sheets at December 31 were:

in $ millions20232022
Deferred income taxes, noncurrent assets(98)(79)
Deferred income taxes, noncurrent liabilities2,7382,885
Total net deferred tax liabilities2,6402,806

At December 31, 2023, the Company had gross loss carryforwards of $1,295 million related to foreign operations and $32 million of state net operating loss carryforwards. $332 million of certain foreign and state loss carryforwards have various expiration dates ranging from 2024 to 2050; $931 million do not expire based on current tax legislation. The Company had gross interest deduction carryforwards of $2,115 million related to foreign operations. $74 million of certain interest carryforwards have various expiration dates ranging from 2024 to 2044, $2,041 million do not expire based on current tax legislation.
The summary of the change in valuation allowance at December 31 was:

in $ millions202320222021
Balance at January 1737578507
Provision for income taxes151203102
Foreign currency and other26(44)(31)
Balance at December 31914737578
The Company maintains a valuation allowance on net operating losses and other deferred tax assets if, based on the weight of available evidence, it is more likely than not that some portion, or all, of a deferred tax asset will not be realized. At December 31, 2023 and December 31, 2022, the Company has a valuation allowance on net deferred tax assets of $914 million and $737 million, respectively. For the year ended December 31, 2023, the valuation allowance increased due to an increase in interest deduction carryforwards.
A deferred tax liability has been recognized in respect of any undistributed earnings in which the Company is not permanently reinvested. The Company has $16.4 billion of undistributed earnings that are considered permanently reinvested at December 31, 2023, for which no deferred tax liabilities have been recognized. It is not practicable to estimate the amount of tax that would be paid if there was a distribution of these earnings. Participation exemptions and tax credits are available in the majority of jurisdictions in which the Company operates.
The reconciliation of the changes in the unrecognized tax benefits at December 31 was:

in $ millions202320222021
Balance at January 1576547536
Increases related to prior periods942
Decreases related to prior periods(12)(8)(21)
Increases related to current period148130104
Decreases related to settlements with taxing authorities and lapse of statute of limitations(68)(67)(56)
Foreign currency and other12(30)(18)
Balance at December 31665576547

The Company files income tax returns in Ireland, the United States, the United Kingdom, Germany, Canada, and other various foreign jurisdictions and is subject to ongoing examination by tax authorities throughout the world. In general, the Company is no longer subject to significant income tax examinations by tax authorities in the jurisdictions noted for years before 2016. The Company believes that its income tax reserves are adequately maintained taking into consideration both the technical merits of its tax return positions and ongoing developments in its income tax audits. However, the final determination of the Company's tax return positions, if audited, is uncertain and therefore there is a possibility that the outcomes of such events could cause the Company’s estimate to change in the future. No single position is expected to generate a significant increase or decrease to the liability for unrecognized tax benefits within 12 months of the reporting date. At December 31, 2023 and December 31, 2022, the unrecognized tax benefits that, if recognized, would impact the effective tax rate were $627 million and $537 million, respectively.
The Company’s policy is to accrue interest and penalties related to potential underpayment of income taxes within the provision for income taxes. At December 31, 2023 and December 31, 2022, the Company had accrued interest of $84 million and $68 million, respectively. At December 31, 2023, December 31, 2022, and December 31, 2021, the interest and penalties included in income tax expense was $14 million, $5 million, and $12 million, respectively.