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Income Taxes Income Taxes (Notes) | 12 Months Ended
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Dec. 31, 2020
Income Tax Disclosure [Abstract] |
Income Tax Disclosure [Text Block] | INCOME TAXES:As a partnership, we are not subject to United States federal income tax and most state income taxes. However, the Partnership conducts certain activities through corporate subsidiaries which are subject to federal and state income taxes. The components of the federal and state income tax expense (benefit) of our taxable subsidiaries were summarized as follows:
| Years Ended December 31,
| 2020 |  | 2019 |  | 2018
Current expense (benefit): |  |  |  |  |
Federal | $ | (6) |  |  | $ | (20) |  |  | $ | (8) |
State | 32 |  |  | (2) |  |  | 19 |
Foreign | 1 |  |  | — |  |  | — |
Total | 27 |  |  | (22) |  |  | 11 |
Deferred expense (benefit): |  |  |  |  |
Federal | 176 |  |  | 174 |  |  | 181 |
State | 41 |  |  | 43 |  |  | (188) |
Foreign | (7) |  |  | — |  |  | — |
Total | 210 |  |  | 217 |  |  | (7) |
Total income tax expense from continuing operations | $ | 237 |  |  | $ | 195 |  |  | $ | 4 |
Historically, our effective tax rate has differed from the statutory rate primarily due to partnership earnings that are not subject to United States federal and most state income taxes at the partnership level. A reconciliation of income tax expense at the United States statutory rate to the Partnership’s income tax benefit for the years ended December 31, 2020, 2019 and 2018 is as follows:
| Years Ended December 31,
| 2020 |  |  |  |  |  | 2019 |  | 2018
Income tax expense at United States statutory rate | $ | 79 |  |  |  |  |  |  | $ | 1,054 |  |  | $ | 775 |
Increase (reduction) in income taxes resulting from: |  |  |  |  |  |  |  |  |
Partnership earnings not subject to tax | 88 |  |  |  |  |  |  | (866) |  |  | (647) |
Noncontrolling interests | 16 |  |  |  |  |  |  | — |  |  | — |
State tax, net of federal tax benefit | 58 |  |  |  |  |  |  | 12 |  |  | (125) |
Dividend received deduction | — |  |  |  |  |  |  | (3) |  |  | (5) |
Foreign taxes | (7) |  |  |  |  |  |  | — |  |  | — |
Other | 3 |  |  |  |  |  |  | (2) |  |  | 6 |
Income tax expense from continuing operations | $ | 237 |  |  |  |  |  |  | $ | 195 |  |  | $ | 4 |
Deferred taxes result from the temporary differences between financial reporting carrying amounts and the tax basis of existing assets and liabilities. The table below summarizes the principal components of the deferred tax assets (liabilities) as follows:
| December 31,
| 2020 |  | 2019
Deferred income tax assets: |  |  |
Net operating losses, alternative minimum tax credit and other carryforwards | $ | 1,047 |  |  | $ | 936 |
Pension and other postretirement benefits | — |  |  | 7 |
Other | 34 |  |  | 85 |
Total deferred income tax assets | 1,081 |  |  | 1,028 |
Valuation allowance | (134) |  |  | (95) |
Net deferred income tax assets | 947 |  |  | 933 |
Deferred income tax liabilities: |  |  |
Property, plant and equipment | (298) |  |  | (501) |
Investments in affiliates | (3,994) |  |  | (3,547) |
Trademarks | (77) |  |  | (72) |
Other | (6) |  |  | (21) |
Total deferred income tax liabilities | (4,375) |  |  | (4,141) |
Net deferred income taxes | $ | (3,428) |  |  | $ | (3,208) |
As of December 31, 2020, ETP Holdco had a federal net operating loss carryforward of $3.73 billion, of which $1.3 billion will expire in 2031 through 2037 while the remaining can be carried forward indefinitely. A total of $787 million of the federal net operating loss carryforward is limited under IRC §382. Although we expect to fully utilize the IRC §382 limited federal net operating loss, the amount utilized in a particular year may be limited. As of December 31, 2020, Sunoco Property Company LLC, a corporate subsidiary of Sunoco LP, had a state net operating loss carrryforward of $121 million, which we expect to fully utilize. Sunoco Property Company LLC has no federal net operating loss carryforward. Our corporate subsidiaries have state net operating loss carryforward benefits of $174 million, net of federal tax, some of which expire between 2021 and 2039, while others are carried forward indefinitely. Our corporate subsidiaries have Canadian net operating losses of $7 million that will begin to expire in 2033. Our corporate subsidiaries have cumulative excess business interest expense of $129 million available for carryforward indefinitely. A valuation allowance of $89 million is attributable to state net operating loss carryforward benefits primarily attributable to significant restrictions on their use in the Commonwealth of Pennsylvania. A separate valuation allowance of $45 million is attributable to foreign tax credits. The following table sets forth the changes in unrecognized tax benefits:
| Years Ended December 31,
| 2020 |  | 2019 |  | 2018
Balance at beginning of year | $ | 94 |  |  | $ | 624 |  |  | $ | 609 |
Additions attributable to tax positions taken in the current year | — |  |  | — |  |  | 8 |
Additions attributable to tax positions taken in prior years | — |  |  | 11 |  |  | 7 |
Reduction attributable to tax positions taken in prior years | — |  |  | (541) |  |  | — |
Lapse of statute | (4) |  |  | — |  |  | — |
Balance at end of year | $ | 90 |  |  | $ | 94 |  |  | $ | 624 |
As of December 31, 2020, we had $90 million ($48 million after federal income tax benefits) related to tax positions which, if recognized, would impact our effective tax rate. Our policy is to accrue interest expense and penalties on income tax underpayments (overpayments) as a component of income tax expense. During 2020, we recognized interest and penalties of less than $7 million. At December 31, 2020, we have interest and penalties accrued of $10 million, net of tax. We appealed the adverse Court of Federal Claims decision against ETC Sunoco regarding the IRS’ denial of ethanol blending credits claims under Section 6426 to the Federal Circuit. The Federal Circuit affirmed the CFC’s denial on November 1, 2018. ETC Sunoco filed a petition for certiorari with the Supreme Court on May 24, 2019 to review the Federal Circuit's affirmation of the CFC's ruling, and the Court denied Sunoco's petition on October 7, 2019. The petition for certiorari applied to ETC Sunoco’s 2004 through 2009 tax years, and 2010 through 2011 remained on extension with the IRS through September 28, 2020. We filed a petition for the 2010 and 2011 years in the Federal District Court for the Northern District of Texas on September 25, 2020. Due to the uncertainty surrounding the litigation, a reserve of $530 million was previously established for the full amount of the pending refund claims, and the receivable and reserve for this issue were netted in the consolidated balance sheet. Subsequent to the Supreme Court’s denial of the petition in October 2019, the receivable and reserve have been reversed, with no impact to the Partnership’s financial position and results of operations. In November 2015, the Pennsylvania Commonwealth Court determined in Nextel Communications v. Commonwealth (“Nextel”) that the Pennsylvania limitation on NOL carryforward deductions violated the uniformity clause of the Pennsylvania Constitution and struck the NOL limitation in its entirety. In October 2017, the Pennsylvania Supreme Court affirmed the decision with respect to the uniformity clause violation; however, the Court reversed with respect to the remedy and instead severed the flat-dollar limitation, leaving the percentage-based limitation intact. Nextel subsequently filed a petition for writ of certiorari with the United States Supreme Court, and this was denied on June 11, 2018. Now certain Pennsylvania taxpayers are proceeding with litigation in Pennsylvania state courts on issues not addressed by the Pennsylvania Supreme Court in Nextel, specifically, whether the Due Process and Equal Protection Clauses of the United States Constitution and the Remedies Clause of the Pennsylvania Constitution require a court to grant the taxpayer relief. ETC Sunoco has recognized approximately $67 million ($53 million after federal income tax benefits) in tax benefit based on previously filed tax returns and certain previously filed protective claims as relates to its cases currently held pending the Nextel matter. However, based upon the Pennsylvania Supreme Court’s October 2017 decision, and because of uncertainty in the breadth of the application of the decision, we have reserved $34 million ($27 million after federal income tax benefits) against the receivable. In general, ET and its subsidiaries are no longer subject to examination by the IRS, and most state jurisdictions, for the 2014 and prior tax years. ET and its subsidiaries also have various state and local income tax returns in the process of examination or administrative appeal in various jurisdictions. We believe the appropriate accruals or unrecognized tax benefits have been recorded for any potential assessment with respect to these examinations.

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- Definition The entire disclosure for income taxes. Disclosures may include net deferred tax liability or asset recognized in an enterprise's statement of financial position, net change during the year in the total valuation allowance, approximate tax effect of each type of temporary difference and carryforward that gives rise to a significant portion of deferred tax liabilities and deferred tax assets, utilization of a tax carryback, and tax uncertainties information. + References Reference 1: http://www.xbrl.org/2003/role/disclosureRef -Publisher FASB -Name Accounting Standards Codification -Topic 740 -SubTopic 10 -Section 50 -Paragraph 21 -URI http://asc.fasb.org/extlink&oid=84230637&loc=d3e32857-109319 Reference 2: http://www.xbrl.org/2003/role/disclosureRef -Publisher FASB -Name Accounting Standards Codification -Topic 740 -SubTopic 10 -Section S99 -Paragraph 2 -Subparagraph (SAB Topic 11.C) -URI http://asc.fasb.org/extlink&oid=116825942&loc=d3e330215-122817 Reference 3: http://www.xbrl.org/2003/role/disclosureRef -Publisher FASB -Name Accounting Standards Codification -Topic 740 -SubTopic 10 -Section 50 -Paragraph 17 -Subparagraph (b) -URI http://asc.fasb.org/extlink&oid=84230637&loc=d3e32809-109319 Reference 4: http://www.xbrl.org/2003/role/disclosureRef -Publisher FASB -Name Accounting Standards Codification -Topic 740 -SubTopic 10 -Section S99 -Paragraph 1 -Subparagraph (SAB TOPIC 6.I.5.Q1) -URI http://asc.fasb.org/extlink&oid=116825942&loc=d3e330036-122817 Reference 5: http://www.xbrl.org/2003/role/disclosureRef -Publisher FASB -Name Accounting Standards Codification -Topic 740 -SubTopic 10 -Section 50 -Paragraph 14 -URI http://asc.fasb.org/extlink&oid=84230637&loc=d3e32705-109319 Reference 6: http://www.xbrl.org/2003/role/disclosureRef -Publisher FASB -Name Accounting Standards Codification -Topic 740 -SubTopic 270 -Section 50 -Paragraph 1 -URI http://asc.fasb.org/extlink&oid=6424409&loc=d3e44925-109338 Reference 7: http://www.xbrl.org/2003/role/disclosureRef -Publisher FASB -Name Accounting Standards Codification -Topic 740 -URI http://asc.fasb.org/topic&trid=2144680 Reference 8: http://www.xbrl.org/2003/role/disclosureRef -Publisher FASB -Name Accounting Standards Codification -Topic 740 -SubTopic 30 -Section 50 -Paragraph 2 -Subparagraph (a) -URI http://asc.fasb.org/extlink&oid=6424122&loc=d3e41874-109331 + Details
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