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Income Taxes
 9 Months Ended
Sep. 30, 2021
Income Tax Disclosure [Abstract]  
Income Taxes Income Taxes
The Company’s income tax provision and effective income tax rate were as follows:
Three Months Ended
September 30,		Nine Months Ended
September 30,
(In millions)2021202020212020
Income tax provision$54 $124 $300 $176 
Effective income tax rate11.3 %32.5 %23.7 %21.1 %
The income tax provision as a percentage of income before income taxes and income from investments in unconsolidated affiliates was 11.3% and 32.5% for the three months ended September 30, 2021 and 2020, respectively, and was 23.7% and 21.1% for the nine months ended September 30, 2021 and 2020, respectively.
The effective income tax rate for the three months ended September 30, 2021 includes discrete tax benefits from subsidiary restructurings and changes in uncertain tax positions. The effective income tax rate for the three months ended September 30, 2020 included $32 million of income tax expense related to the revaluation of certain net deferred tax liabilities as a result of an increase in the United Kingdom corporate income tax rate from 17% to 19% in the quarter.
The effective income tax rate for the nine months ended September 30, 2021 includes $134 million of income tax expense attributed to the revaluation of certain net deferred tax liabilities, primarily related to intangible assets and investments in joint ventures recognized at fair value in connection with the acquisition of First Data, reflecting the effect of enacted corporate income tax rate changes in the United Kingdom (tax rate increase from 19% to 25% starting in 2023) and Argentina (tax rate increase from 25% to 35%), partially offset by discrete tax benefits from subsidiary restructurings, changes in uncertain tax positions and equity compensation related tax benefits. The effective income tax rate for the nine months ended September 30, 2020 included $112 million of income tax expense associated with the $428 million gain on the sale of a 60% interest of the Company’s Investment Services business (see Note 4) and $32 million of income tax expense noted above, partially offset by changes in uncertain tax positions and equity compensation related tax benefits.
The Company’s potential liability for unrecognized tax benefits before interest and penalties was approximately $136 million at September 30, 2021. The Company believes it is reasonably possible that the liability for unrecognized tax benefits may decrease by up to $26 million over the next twelve months as a result of possible closure of federal tax audits, potential settlements with certain states, and the lapse of the statutes of limitation in various jurisdictions.
As of September 30, 2021, the Company’s U.S. federal income tax return for 2020, and tax returns in certain states and foreign jurisdictions for 2005 through 2020, remain subject to examination by taxing authorities. State and local examinations are substantially complete through 2014 in relation to First Data’s state and local tax filings. Foreign jurisdictions generally remain subject to examination by their respective authorities from 2010 forward in relation to First Data’s foreign tax filings, none of which are considered significant jurisdictions.