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Income Taxes
12 Months Ended
Dec. 31, 2020
Income Tax Disclosure [Abstract]  
Income taxes Income taxes
Income before income taxes is comprised of the following components:
For Years Ended December 31,
202020192018
U.S.$5,210 $4,915 $5,672 
Non-U.S.807 813 1,014 
Total$6,017 $5,728 $6,686 
Provision for income taxes is comprised of the following components:
For Years Ended December 31,
202020192018
CurrentDeferredTotalCurrentDeferredTotalCurrentDeferredTotal
U.S. federal$357 $(122)$235 $483 $25 $508 $979 $(98)$881 
Non-U.S.192 (15)177 135 56 191 225 (8)217 
U.S. state10  10 12 — 12 
Total$559 $(137)$422 $630 $81 $711 $1,211 $(105)$1,106 
Principal reconciling items from the U.S. statutory income tax rate to the effective tax rate (provision for income taxes as a percentage of income before income taxes) are as follows:
For Years Ended December 31,
202020192018
U.S. statutory income tax rate21.0 %21.0 %21.0 %
U.S. tax benefit for foreign derived intangible income(6.1)(4.9)(5.3)
Impact of changes in uncertain tax positions(4.0)(0.1)— 
U.S. excess tax benefit for stock compensation(2.5)(3.1)(2.0)
U.S. R&D tax credit(1.3)(1.4)(1.3)
U.S. Tax Act transitional non-cash expense — 4.2 
Other(0.1)0.9 (0.1)
Effective tax rate7.0 %12.4 %16.5 %
The earnings represented by non-cash operating assets, such as fixed assets and inventory, will continue to be permanently reinvested outside the United States. Provisions of the U.S. Tax Cuts and Jobs Act (the Tax Act), such as the one-time tax on indefinitely reinvested earnings and the global intangible low-taxed income (GILTI) tax for years beginning in 2018, eliminate any additional U.S. taxation resulting from repatriation of earnings of non-U.S. subsidiaries to the United States. Consequently, no U.S. tax provision has been made for the future remittance of these earnings. However, withholding or distribution taxes in certain non-U.S. jurisdictions will be incurred upon repatriation of available cash to the United States. A provision has been made for deferred taxes on these undistributed earnings to the extent that repatriation of the available cash to the United States is expected to result in a tax liability. As of December 31, 2020, we have no basis differences that would result in material unrecognized deferred tax liabilities.
We have made an allowable policy election to account for the effects of GILTI as a component of income tax expense in the period in which the tax is incurred.
The primary components of deferred tax assets and liabilities are as follows:
December 31,
20202019
Deferred tax assets:
Deferred loss and tax credit carryforwards$207 $213 
Accrued expenses180 182 
Stock compensation106 109 
Inventories and related reserves105 109 
Retirement costs for defined benefit and retiree health care44 49 
Other3 — 
Total deferred tax assets, before valuation allowance645 662 
Valuation allowance(179)(180)
Total deferred tax assets, after valuation allowance466 482 
Deferred tax liabilities:
Property, plant and equipment(116)(164)
International earnings(44)(62)
Acquisition-related intangibles and fair-value adjustments(40)(82)
Other(13)(55)
Total deferred tax liabilities(213)(363)
Net deferred tax asset$253 $119 
The deferred tax assets and liabilities based on tax jurisdictions are presented on our Consolidated Balance Sheets as follows:
December 31,
20202019
Deferred tax assets$343 $197 
Deferred tax liabilities(90)(78)
Net deferred tax asset$253 $119 
We make an ongoing assessment regarding the realization of U.S. and non-U.S. deferred tax assets. This assessment is based on our evaluation of relevant criteria, including the existence of deferred tax liabilities that can be used to absorb deferred tax assets, taxable income in prior carryback years and expectations for future taxable income. Valuation allowances decreased $1 million in 2020 and increased $8 million and $7 million in 2019 and 2018, respectively. These changes had no impact to net income in 2020, 2019 or 2018.
We have no tax loss carryforwards as of December 31, 2020.
Cash payments made for income taxes, net of refunds, were $720 million, $570 million and $705 million in 2020, 2019 and 2018, respectively.
Uncertain tax positions
We operate in a number of tax jurisdictions, and our income tax returns are subject to examination by tax authorities in those jurisdictions who may challenge any item on these tax returns. Because the matters challenged by authorities are typically complex, their ultimate outcome is uncertain. Before any benefit can be recorded in our financial statements, we must determine that it is “more likely than not” that a tax position will be sustained by the appropriate tax authorities. We recognize accrued interest related to uncertain tax positions and penalties as components of OI&E.
The changes in the total amounts of uncertain tax positions are as follows:
202020192018
Balance, January 1$303 $286 $300 
Additions based on tax positions related to the current year3 
Additions for tax positions of prior years35 63 
Reductions for tax positions of prior years(249)(41)— 
Settlements with tax authorities (8)(18)
Expiration of the statute of limitations for assessing taxes(3)— — 
Balance, December 31$89 $303 $286 
Interest income (expense) recognized in the year ended December 31$39 $$(15)
Interest payable as of December 31$8 $44 $49 
The liability for uncertain tax positions is a component of other long-term liabilities on our Consolidated Balance Sheets.
All of the $89 million and $303 million liabilities for uncertain tax positions as of December 31, 2020 and 2019, respectively, are comprised of positions that, if recognized, would lower the effective tax rate. If these liabilities are ultimately realized, $2 million of existing deferred tax assets in both 2020 and 2019 would also be realized. Reductions for tax positions of prior years in 2020 include a $249 million tax benefit for the effective settlement of a depreciation-related uncertain tax position. Accrued interest of $46 million related to this uncertain tax position was reversed and included in OI&E.
As of December 31, 2020, the statute of limitations remains open for U.S. federal tax returns for 2013 and following years. Audit activities related to our U.S. federal tax returns through 2015 have been completed except for certain pending tax treaty procedures for relief from double taxation and an Internal Revenue Service appeals process related to the 2013 through 2015 audit. The procedures for relief from double taxation pertain to U.S. federal tax returns for the years 2007 through 2012.
In non-U.S. jurisdictions, the years open to audit represent the years still open under the statute of limitations. With respect to major jurisdictions outside the United States, our subsidiaries are no longer subject to income tax audits for years before 2007.