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Income Taxes
 12 Months Ended
Dec. 31, 2024
Income Tax Disclosure [Abstract]  
Income Taxes Income Taxes
The domestic and foreign components of Income before income taxes were as follows (in millions):

 Year Ended December 31,
 202220232024
Domestic$1,820 $1,913 $3,047 
Foreign169 189 284 
Income before income taxes$1,989 $2,102 $3,331 

The components of the provision for (benefit from) income taxes were as follows (in millions):

 Year Ended December 31,
 202220232024
Current
Federal$19 $19 $103 
State10 8 23 
Foreign68 158 124 
Total current provision for income taxes97 185 250 
Deferred
Federal— (2,410)397 
State— (461)36 
Foreign(1)(4)— 
Total deferred provision for (benefit from) income taxes(1)(2,875)433 
Total provision for (benefit from) income taxes$96 $(2,690)$683 
The following is a reconciliation of the U.S. federal statutory federal income tax rate to the Company’s effective tax rate:

 Year Ended December 31,
 202220232024
Expected income tax expense at U.S. federal statutory rate
21.0 %21.0 %21.0 %
State taxes, net of federal benefits0.4 0.3 1.3 
Foreign tax rate differential1.0 2.9 0.8 
Stock-based compensation(6.9)(16.7)(0.2)
Other statutorily non-deductible expenses0.3 0.1 0.1 
Research and development credits(4.7)(5.5)(2.2)
Uncertain tax positions—prior year positions0.1 1.8 — 
Uncertain tax positions—current year positions0.8 1.7 1.4 
U.S. tax on foreign income, net of allowable credits and deductions0.7 3.9 — 
Foreign-derived intangible income deduction(1.9)(1.0)(2.0)
Change in valuation allowance
(6.0)(136.6)0.3 
Other, net
— 0.1 — 
Effective tax rate4.8 %(128.0)%20.5 %

The components of deferred tax assets and liabilities consisted of the following (in millions):

 December 31,
 20232024
Deferred tax assets:
Loss carryforwards
$1,232 $462 
Tax credit carryforwards844 999 
Accruals and reserves113 122 
Non-income tax accruals78 84 
Stock-based compensation70 70 
Operating lease liabilities62 61 
Intangible assets158 140 
Capitalized research and development costs671 882 
Other, net
55 62 
Gross deferred tax assets3,283 2,882 
Valuation allowance(364)(395)
Total deferred tax assets2,919 2,487 
Deferred tax liabilities:
Property and equipment basis differences(18)(20)
Operating lease assets(18)(25)
Other, net
(2)(7)
Total deferred tax liabilities(38)(52)
Total net deferred tax assets$2,881 $2,435 
The Company regularly assesses the need for a valuation allowance against its deferred tax assets each quarter. In making that assessment, the Company considers both positive and negative evidence in the various jurisdictions in which it operates related to the likelihood of realization of the deferred tax assets to determine, based on the weight of available evidence, whether it is more likely than not that some or all of the deferred tax assets will not be realized. As of December 31, 2023, based on all available positive and negative evidence, having demonstrated sustained profitability which is objective and verifiable, and taking into account anticipated future earnings, the Company concluded that it is more likely than not that its U.S. federal and state deferred tax assets will be realizable, with the exception of California research and development credits, capital loss carryovers, and certain losses subject to the dual consolidated loss rules. The Company released $2.9 billion of its valuation allowance during 2023. The Company continues to maintain a valuation allowance against its California research and development credit deferred tax assets due to the uncertainty regarding realizability of these deferred tax assets as they have not met the “more likely than not” realization criteria, particularly as the Company expects research and development tax credit generation to exceed its ability to use the credits in future years. The Company will continue to monitor the need for a valuation allowance against its deferred tax assets on a quarterly basis.

The Company’s policy with respect to its undistributed foreign subsidiaries’ earnings is to consider those earnings to be indefinitely reinvested. The Company has not provided for the tax effect, if any, of limited outside basis differences of its foreign subsidiaries. The determination of the future tax consequences of the remittance of these earnings is not practicable.
As of December 31, 2023 and 2024, the Company had net operating loss carryforwards for federal income tax purposes of $5.3 billion and $1.8 billion, respectively. The Company’s federal net operating loss carryforwards do not have an expiration date. As of December 31, 2023 and 2024, the Company had federal research and development tax credit carryforwards of $720 million and $554 million, respectively. The research and development tax credits will expire beginning in 2041 if not utilized. As of December 31, 2024, the Company had alternative minimum tax credit carryforwards of $311 million, which do not have an expiration date and may be claimed against regular tax in future years.

As of December 31, 2023 and 2024, the Company had net operating loss carryforwards for state income tax purposes of $4.6 billion and $3.8 billion, respectively. Some of the Company’s state net operating loss carryforwards will expire, if not utilized, beginning in 2027. As of December 31, 2023 and 2024, the Company had state research and development tax credit carryforwards of $464 million and $501 million, respectively. The research and development tax credits do not have an expiration date.

The Tax Reform Act of 1986 and similar California legislation impose substantial restrictions on the utilization of net operating losses and tax credit carryforwards in the event that there is a change in ownership as provided by Section 382 of the Internal Revenue Code and similar state provisions. Such a limitation could result in the expiration of the net operating loss carryforwards and tax credits before utilization, which could result in increased future tax liabilities.

A reconciliation of the beginning and ending amount of the Company’s total gross unrecognized tax benefits was as follows (in millions):

 Year Ended December 31,
 202220232024
Balance at beginning of year$597 $650 $780 
Gross increases related to prior year tax positions7 52 1 
Gross decreases related to prior year tax positions(2)(8)(1)
Gross increases related to current year tax positions60 103 106 
Reductions due to settlements with taxing authorities(7)(12)(14)
Reduction due to lapse in statute of limitations(5)(5)(3)
Balance at end of year$650 $780 $869 

The Company is in various stages of examination in connection with its ongoing tax audits globally, and it is difficult to determine when these examinations will be settled. The Company believes that an adequate provision has been recorded for any adjustments that may result from tax audits. However, the outcome of tax audits cannot be predicted with certainty. If any issues addressed in the Company’s tax audits are resolved in a manner not consistent with management’s expectations, the Company may be required to record an adjustment to the provision for (benefit from) income taxes in the period such resolution occurs. Changes in tax laws, regulations, administrative practices, principles, and interpretations may impact the Company’s tax contingencies. The timing of the resolution of income tax examinations is highly uncertain, and the amounts ultimately paid, if any, upon resolution of the issues raised by the taxing authorities may differ from the amounts accrued. It is reasonably possible that within the next twelve months the Company may experience an increase or decrease in its unrecognized tax benefits as a result of additional assessments by various tax authorities, possibly reach resolution of income tax examinations in one or more jurisdictions, or lapses of the statute of limitations. However, an estimate of the range of the reasonably possible change in the next twelve months cannot be made.

As of December 31, 2024, $740 million of unrecognized tax benefits represents the amount that would, if recognized, impact the Company’s effective income tax rate. The Company’s accrual for interest and penalties was $90 million and $100 million as of December 31, 2023 and 2024, respectively.

The Company’s significant tax jurisdictions include the United States, California, and Ireland. The Company is currently under examination for income taxes by the Internal Revenue Service (“IRS”) for the 2013, 2016, 2017, and 2018 tax years. The primary issue under examination in the 2013 audit is the valuation of the Company’s international intellectual property which was sold to a subsidiary in 2013. In the year ended December 31, 2019, new information became available which required the Company to remeasure its reserve for unrecognized tax benefits. The Company recorded additional tax expense of $196 million during the year ended December 31, 2019. In December 2020, the Company received a Notice of Proposed Adjustment (“NOPA”) from the IRS which proposed an increase to the Company’s U.S. taxable income that could result in additional income tax expense and cash liability of $1.3 billion plus penalties and interest, which exceeds its current reserve recorded in its consolidated financial statements by more than $1.0 billion. The Company disagrees with the proposed adjustment and continues to vigorously contest it. In February 2021, the Company submitted a protest to the IRS describing its disagreement with the proposed adjustment and requesting the case be transferred to the IRS Independent Office of Appeals (“IRS Appeals”). In December 2021, the Company received a rebuttal from the IRS with the same proposed adjustments that were in the NOPA. In January 2022, the Company entered into an administrative dispute process with IRS Appeals. An acceptable outcome was not reached with IRS Appeals, and in May 2024, the Company received a Statutory Notice of Deficiency (“Notice”) from the IRS related to the aforementioned valuation of its international intellectual property. The Notice claims that the Company owes $1.3 billion in tax, plus penalties and interest. The Company will continue to pursue all available remedies to resolve this dispute. In July 2024, the Company petitioned the U.S. Tax Court (“Tax Court”) for redetermination, and if necessary, the Company will appeal the Tax Court’s decision to the appropriate appellate court. The Company believes that adequate amounts have been reserved for any adjustments that may ultimately result from these examinations. If the IRS prevails in the assessment of additional tax due based on its position and such tax and related interest and penalties, if any, exceeds the Company’s current reserves, such outcome could have a material adverse impact on the Company’s financial position and results of operations, and any assessment of additional tax could require a significant cash payment and have a material adverse impact on the Company’s consolidated statements of cash flow.

The Company’s 2008 to 2024 tax years remain subject to examination in the United States and California due to tax attributes and statutes of limitations, and its 2020 to 2024 tax years remain subject to examination in Ireland. There are other ongoing audits in various other
jurisdictions that are immaterial to the Company’s consolidated financial statements. The Company remains subject to possible examination in various other jurisdictions that are not expected to result in material tax adjustments.

On August 16, 2022, the Inflation Reduction Act was signed into law, with tax provisions primarily focused on implementing a 15% minimum tax (CAMT) on global adjusted financial statement income and a 1% excise tax on net share repurchases. The Inflation Reduction Act became effective beginning in fiscal year 2023 and did not have a material impact on the year ended December 31, 2023. The Company accrued $95 million of CAMT liability during the year ended December 31, 2024, and may be subject to a material amount of CAMT in the next year but expect to fully utilize the corresponding tax credits generated from the CAMT in the subsequent following years.