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Income Taxes | 12 Months Ended
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Dec. 31, 2022
Income Tax Disclosure [Abstract] |
Income Taxes | Income Taxes The components of income before income taxes are as follows:
|  | 2022 |  | 2021 |  | 2020
United States |  | $ | 7,305 |  |  | $ | 3,740 |  |  | $ | 4,070 |
Foreign |  | 3,400 |  |  | 6,081 |  |  | 4,999 |
|  | $ | 10,705 |  |  | $ | 9,821 |  |  | $ | 9,069 |
The provision for income taxes consisted of the following:
| 2022 |  | 2021 |  | 2020
Current: |  |  |  |  |
U.S. Federal | $ | 1,137 |  |  | $ | 702 |  |  | $ | 715 |
Foreign | 1,027 |  |  | 955 |  |  | 932 |
State | 246 |  |  | 44 |  |  | 110 |
| 2,410 |  |  | 1,701 |  |  | 1,757 |
Deferred: |  |  |  |  |
U.S. Federal | 22 |  |  | 375 |  |  | 273 |
Foreign | (709) |  |  | (14) |  |  | (167) |
State | 4 |  |  | 80 |  |  | 31 |
| (683) |  |  | 441 |  |  | 137 |
| $ | 1,727 |  |  | $ | 2,142 |  |  | $ | 1,894 |
A reconciliation of the U.S. Federal statutory tax rate to our annual tax rate is as follows:
| 2022 |  | 2021 |  | 2020
U.S. Federal statutory tax rate | 21.0 | % |  | 21.0 | % |  | 21.0 | %
State income tax, net of U.S. Federal tax benefit | 1.8 |  |  | 1.0 |  |  | 1.2 |
Lower taxes on foreign results | (1.5) |  |  | (1.6) |  |  | (0.8) |
One-time mandatory transition tax - TCJ Act | 0.8 |  |  | 1.9 |  |  | — |
Juice Transaction | (2.4) |  |  | — |  |  | — |
Tax settlements | (3.0) |  |  | — |  |  | — |
Other, net | (0.6) |  |  | (0.5) |  |  | (0.5) |
Annual tax rate | 16.1 | % |  | 21.8 | % |  | 20.9 | %
Tax Cuts and Jobs Act In 2022, we recorded $86 million ($0.06 per share) of net tax expense related to the TCJ Act as a result of correlating adjustments related to a partial audit settlement with the IRS for tax years 2014 through 2019. In 2021, we recorded $190 million ($0.14 per share) of net tax expense related to the TCJ Act as a result of adjustments related to the final assessment of the 2014 through 2016 IRS audit. There were no tax amounts recognized in 2020 related to the TCJ Act. As of December 31, 2022, our mandatory transition tax liability was $2.6 billion, which must be paid through 2026 under the provisions of the TCJ Act. We reduced our liability through cash payments and application of tax overpayments by $309 million in 2022, $309 million in 2021 and $78 million in 2020. We currently expect to pay approximately $309 million of this liability in 2023. The TCJ Act also created a requirement that certain income earned by foreign subsidiaries, known as global intangible low-tax income (GILTI), must be included in the gross income of their U.S. shareholder. The FASB allows an accounting policy election of either recognizing deferred taxes for temporary differences expected to reverse as GILTI in future years or recognizing such taxes as a current-period expense when incurred. We elected to treat the tax effect of GILTI as a current-period expense when incurred. Other Tax Matters In 2021, we received a final assessment from the IRS audit for the tax years 2014 through 2016. The assessment included both agreed and unagreed issues. On October 29, 2021, we filed a formal written protest of the assessment and requested an appeals conference. As a result of the analysis of the 2014 through 2016 final assessment, we remeasured all applicable reserves for uncertain tax positions for all years open under the statute of limitations, including any correlating adjustments impacting the mandatory transition tax liability under the TCJ Act, resulting in a net non-cash tax expense of $112 million ($0.08 per share) in 2021. In 2022, we came to an agreement with the IRS to settle one of the issues assessed in the 2014 through 2016 tax audit. The agreement covers tax years 2014 through 2019. As a result, we reduced our reserves for uncertain tax positions, including any correlating adjustments impacting the mandatory transition tax liability under the TCJ Act, resulting in a net non-cash tax benefit of $233 million ($0.17 per share) in 2022. Tax years 2014 through 2019 remain under audit for other issues. On August 16, 2022, the “Inflation Reduction Act” (H.R. 5376) was signed into law in the United States. We do not currently expect the Inflation Reduction Act to have a material impact on our financial results, including on our annual estimated effective tax rate or on our liquidity. On May 19, 2019, a public referendum held in Switzerland passed the Federal Act on Tax Reform and AHV Financing (TRAF), effective January 1, 2020. The enactment of certain provisions of the TRAF resulted in adjustments to our deferred taxes. During 2020, we recorded a net tax benefit of $72 million ($0.05 per share) related to the adoption of the TRAF in the Swiss Canton of Bern. Deferred tax liabilities and assets are comprised of the following:
| 2022 |  | 2021
Deferred tax liabilities |  |  |
Debt guarantee of wholly-owned subsidiary | $ | 578 |  |  | $ | 578 |
Property, plant and equipment | 2,126 |  |  | 2,036 |
Recapture of net operating losses | 492 |  |  | 504 |
Pension liabilities | 189 |  |  | 216 |
Right-of-use assets | 534 |  |  | 450 |
Investment in TBG | 186 |  |  | — |
Other | 232 |  |  | 254 |
Gross deferred tax liabilities | 4,337 |  |  | 4,038 |
Deferred tax assets |  |  |
Net carryforwards | 5,342 |  |  | 4,974 |
Intangible assets other than nondeductible goodwill | 1,614 |  |  | 1,111 |
Share-based compensation | 120 |  |  | 98 |
Retiree medical benefits | 118 |  |  | 147 |
Other employee-related benefits | 349 |  |  | 379 |
Deductible state tax and interest benefits | 144 |  |  | 149 |
Lease liabilities | 534 |  |  | 450 |
Capitalized research and development | 150 |  |  | — |
Other | 1,050 |  |  | 842 |
Gross deferred tax assets | 9,421 |  |  | 8,150 |
Valuation allowances | (5,013) |  |  | (4,628) |
Deferred tax assets, net | 4,408 |  |  | 3,522 |
Net deferred tax (assets)/liabilities | $ | (71) |  |  | $ | 516 |
A summary of our valuation allowance activity is as follows:
| 2022 |  | 2021 |  | 2020
Balance, beginning of year | $ | 4,628 |  |  | $ | 4,686 |  |  | $ | 3,599 |
Provision | 492 |  |  | (9) |  |  | 1,082 |
Other (deductions)/additions | (107) |  |  | (49) |  |  | 5 |
Balance, end of year | $ | 5,013 |  |  | $ | 4,628 |  |  | $ | 4,686 |
Reserves A number of years may elapse before a particular matter, for which we have established a reserve, is audited and finally resolved. The number of years with open tax audits varies depending on the tax jurisdiction. Our major taxing jurisdictions and the related open tax audits are as follows:
Jurisdiction |  | Years Open to Audit |  | Years Currently Under Audit
United States |  | 2014-2021 |  | 2014-2019
Mexico |  | 2014-2021 |  | 2014-2017
United Kingdom |  | 2020-2021 |  | None
Canada (Domestic) |  | 2016-2021 |  | 2016-2019
Canada (International) |  | 2010-2021 |  | 2010-2019
Russia |  | 2019-2021 |  | None
Our annual tax rate is based on our income, statutory tax rates and tax planning strategies and transactions, including transfer pricing arrangements, available to us in the various jurisdictions in which we operate. Significant judgment is required in determining our annual tax rate and in evaluating our tax positions. We establish reserves when, despite our belief that our tax return positions are fully supportable, we believe that certain positions are subject to challenge and that we likely will not succeed. We adjust these reserves, as well as the related interest, in light of changing facts and circumstances, such as the progress of a tax audit, new tax laws, relevant court cases or tax authority settlements. Settlement of any particular issue would usually require the use of cash. Favorable resolution would be recognized as a reduction to our annual tax rate in the year of resolution. As of December 31, 2022, the total gross amount of reserves for income taxes, reported in other liabilities, was $1.9 billion. We accrue interest related to reserves for income taxes in our provision for income taxes and any associated penalties are recorded in selling, general and administrative expenses. The gross amount of interest accrued, reported in other liabilities, was $292 million as of December 31, 2022, of which $4 million of tax benefit was recognized in 2022. The gross amount of interest accrued, reported in other liabilities, was $326 million as of December 25, 2021, of which $3 million of tax benefit was recognized in 2021. A reconciliation of unrecognized tax benefits is as follows:
| 2022 |  | 2021
Balance, beginning of year | $ | 1,900 |  |  | $ | 1,621 |
Additions for tax positions related to the current year | 228 |  |  | 222 |
Additions for tax positions from prior years | 206 |  |  | 681 |
Reductions for tax positions from prior years | (357) |  |  | (558) |
Settlement payments | (53) |  |  | (25) |
Statutes of limitations expiration | (36) |  |  | (39) |
Translation and other | (21) |  |  | (2) |
Balance, end of year | $ | 1,867 |  |  | $ | 1,900 |
Carryforwards and Allowances Operating loss carryforwards totaling $32.2 billion as of December 31, 2022 are being carried forward in a number of foreign and state jurisdictions where we are permitted to use tax operating losses from prior periods to reduce future taxable income. These operating losses will expire as follows: $0.2 billion in 2023, $27.6 billion between 2024 and 2041 and $4.4 billion may be carried forward indefinitely. We establish valuation allowances for our deferred tax assets if, based on the available evidence, it is not more likely than not that some portion or all of the deferred tax assets will be realized. Undistributed International Earnings As of December 31, 2022, we had approximately $9 billion of undistributed international earnings. We intend to continue to reinvest $9 billion of earnings outside the United States for the foreseeable future and while future distribution of these earnings would not be subject to U.S. federal tax expense, no deferred tax liabilities with respect to items such as certain foreign exchange gains or losses, foreign withholding taxes or state taxes have been recognized. It is not practicable for us to determine the amount of unrecognized tax expense on these reinvested international earnings.

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