8. INCOME TAXES

The provision for income taxes by taxing jurisdiction and by significant component consisted of the following in millions of dollars:


	2015		2014		2013

Current:
U.S.:
Federal	$	377	$	1,217	$	1,405
State		32		126		145
Foreign		449		564		569
Total current		858		1,907		2,119
Deferred:
U.S.:
Federal		21		(189)		(117)
State		4		(11)		(11)
Foreign		(43)		(80)		(45)
Total deferred		(18)		(280)		(173)
Provision for income taxes	$	840	$	1,627	$	1,946

Based upon the location of the company’s operations, the consolidated income before income taxes in the U.S. in 2015, 2014 and 2013 was $1,838 million, $3,219 million and $4,124 million, respectively, and in foreign countries was $942 million, $1,578 million and $1,359 million, respectively. Certain foreign operations are branches of Deere & Company and are subject to U.S. as well as foreign income tax regulations. The pretax income by location and the preceding analysis of the income tax provision by taxing jurisdiction are not directly related.

A comparison of the statutory and effective income tax provision and reasons for related differences in millions of dollars follow:


	2015		2014		2013


U.S. federal income tax provision at a statutory rate of 35 percent	$	973	$	1,679	$	1,919
Increase (decrease) resulting from:
State and local income taxes, net of federal income tax benefit		23		75		87
German branch deferred tax write-off						56
Differences in taxability of foreign (earnings) losses		(449)		(305)		43
Nondeductible impairment charges				32		29
Research and business tax credits		(76)		(99)		(56)
Tax rates on foreign earnings		(36)		(71)		(34)
Valuation allowance on deferred taxes		384		454		(14)
Other-net		21		(138)		(84)
Provision for income taxes	$	840	$	1,627	$	1,946

At October 31, 2015, accumulated earnings in certain subsidiaries outside the U.S. totaled $5,282 million for which no provision for U.S. income taxes or foreign withholding taxes has been made, because it is expected that such earnings will be reinvested outside the U.S. indefinitely. Determination of the amount of unrecognized deferred tax liability on these unremitted earnings is not practicable. At October 31, 2015, the amount of cash and cash equivalents and marketable securities held by these foreign subsidiaries was $1,588 million.

Deferred income taxes arise because there are certain items that are treated differently for financial accounting than for income tax reporting purposes. An analysis of the deferred income tax assets and liabilities at October 31 in millions of dollars follows:


	2015				2014
	Deferred		Deferred		Deferred		Deferred
	Tax		Tax		Tax		Tax
	Assets		Liabilities		Assets		Liabilities

Other postretirement benefit liabilities	$	1,972			$	1,968
Tax over book depreciation			$	574			$	542
Accrual for sales allowances		618				654
Lease transactions				528				404
Tax loss and tax credit carryforwards		604				514
Foreign unrealized losses		458				146
Pension liability - net		315				160
Accrual for employee benefits		172				229
Share-based compensation		141				145
Inventory						22
Goodwill and other intangible assets				80				89
Allowance for credit losses		72				73
Deferred gains on distributed foreign earnings		33				32
Deferred compensation		51				47
Undistributed foreign earnings				25				26
Other items		436		119		440		116
Less valuation allowances		(940)				(637)
Deferred income tax assets and liabilities	$	3,932	$	1,326	$	3,793	$	1,177

Deere & Company files a consolidated federal income tax return in the U.S., which includes the wholly-owned financial services subsidiaries. These subsidiaries account for income taxes generally as if they filed separate income tax returns.

At October 31, 2015, certain tax loss and tax credit carryforwards of $604 million, of which $88 million are capital losses, were available with $226 million expiring from 2016 through 2035 and $378 million with an indefinite carryforward period.

In March 2013, the company changed the corporate structure of most of its German operations from a branch to a subsidiary of Deere & Company. The change provides the company increased flexibility and efficiency in funding growth in international operations. As a result, the tax status of these operations changed. Formerly, as a branch these earnings were taxable in the U.S. as earned. As a subsidiary, these earnings are now taxable in the U.S. if they are distributed to Deere & Company as dividends, which is the same as the company’s other foreign subsidiaries. The earnings of the new German subsidiary remain taxable in Germany. Due to the change in tax status and the expectation that the German subsidiary’s earnings are indefinitely reinvested, the deferred tax assets and liabilities related to U.S. taxable temporary differences for the previous German branch were written off. The effect of this write-off was a decrease in net deferred tax assets and a charge to the income tax provision of $56 million during the second fiscal quarter of 2013.

A reconciliation of the total amounts of unrecognized tax benefits at October 31 in millions of dollars follows:


	2015		2014		2013

Beginning of year balance	$	213	$	272	$	265
Increases to tax positions taken during the current year		32		28		30
Increases to tax positions taken during prior years		29		20		24
Decreases to tax positions taken during prior years		(15)		(84)		(51)
Decreases due to lapse of statute of limitations		(11)		(4)		(5)
Settlements		(6)
Foreign exchange		(13)		(19)		9
End of year balance	$	229	$	213	$	272

The amount of unrecognized tax benefits at October 31, 2015 that would affect the effective tax rate if the tax benefits were recognized was $79 million. The remaining liability was related to tax positions for which there are offsetting tax receivables, or the uncertainty was only related to timing. The company expects that any reasonably possible change in the amounts of unrecognized tax benefits in the next twelve months would not be significant.

The company files its tax returns according to the tax laws of the jurisdictions in which it operates, which includes the U.S. federal jurisdiction, and various state and foreign jurisdictions. The U.S. Internal Revenue Service has completed the examination of the company’s federal income tax returns for periods prior to 2009. The years 2009 through 2012 federal income tax returns are currently under examination. Various state and foreign income tax returns, including major tax jurisdictions in Canada and Germany, also remain subject to examination by taxing authorities.

The company’s policy is to recognize interest related to income taxes in interest expense and interest income, and recognize penalties in selling, administrative and general expenses. During 2015, 2014 and 2013, the total amount of expense from interest and penalties was $23 million, $11 million and $9 million and the interest income was $3 million, $4 million and $4 million, respectively. At October 31, 2015 and 2014, the liability for accrued interest and penalties totaled $69 million and $54 million and the receivable for interest was $2 million and $2 million, respectively.