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Income Taxes | 6 Months Ended
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Jun. 30, 2021
Income Tax Disclosure [Abstract] |
Income Taxes | Note 9 – Income Taxes We compute our quarterly income tax expense/(benefit) by using a forecasted annual effective tax rate and adjust for any discrete items arising during the quarter. We recorded an income tax expense/(benefit) of $4 million and $(238) million for the three and six months ended June 30, 2020, respectively, and $(479) million and $(294) million for the three and six months ended June 30, 2021, respectively. During the three months ended June 30, 2020, the income tax expense was primarily driven by current tax on foreign earnings offset by a partial benefit from U.S. losses. During the six months ended June 30, 2020, the income tax benefit was primarily driven by the deferred U.S. tax impact of the impairment charges related to our investments in Didi and Grab, the deferred China tax impact of the impairment charge related to our investment in Didi, and to a lesser extent, the benefit of U.S. losses and current tax on foreign earnings. During the three and six months ended June 30, 2021, the income tax benefit was primarily driven by the deferred China and US tax impact related to our investment in Didi, the deferred tax impact related to our investment in Aurora, and to a lesser extent, by the benefit from our US losses and current tax on our foreign earnings. The primary differences between the effective tax rate and the federal statutory tax rate are due to the China and US deferred taxes related to our investment in Didi, US deferred taxes related to our investment in Aurora, the valuation allowance on our US and Netherlands' deferred tax assets, and foreign tax rate differences. During the six months ended June 30, 2021, the amount of gross unrecognized tax benefits increased by $165 million, of which approximately $53 million of unrecognized tax benefits, if recognized, would impact the effective tax rate. The remaining $112 million of unrecognized tax benefits would not impact the effective tax rate due to the valuation allowance against certain deferred tax assets. We are subject to taxation in the U.S. and various state and foreign jurisdictions. We are also under routine examination by federal, various state and foreign tax authorities. We believe that adequate amounts have been reserved in these jurisdictions. To the extent we have tax attribute carryforwards, the tax years in which the attribute was generated may still be adjusted upon examination by the federal, state or foreign tax authorities to the extent utilized in a future period. For our major tax jurisdictions, the tax years 2002 through 2021 remain open; the major tax jurisdictions are the U.S., Brazil, Netherlands, and Australia. Although the timing of the resolution and/or closure of audits is highly uncertain, we do not expect any material changes to our unrecognized tax benefits within the next 12 months. Given the number of years remaining subject to examination and the number of matters being examined, we are unable to estimate the full range of possible adjustments to the balance of gross unrecognized tax benefits. In the event we experience an ownership change within the meaning of Section 382 of the Internal Revenue Code (“IRC”), our ability to utilize net operating losses, tax credits and other tax attributes may be limited. The most recent analysis of our historical ownership changes was completed through June 30, 2021. Based on the analysis, we do not anticipate a current limitation on the tax attributes.

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