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INCOME TAXES
 12 Months Ended
Oct. 31, 2021
Income Tax Disclosure [Abstract]  
INCOME TAXES INCOME TAXES
The domestic and foreign components of income before taxes are:

 Years Ended October 31,
 202120202019
 (in millions)
U.S. operations$876 $54 $189 
Non-U.S. operations484 788 730 
Total income before taxes$1,360 $842 $919 
The provision for income taxes is comprised of:

 Years Ended October 31,
 202120202019
 (in millions)
U.S. federal taxes:   
Current$122 $5 $(191)
Deferred(1)4 — 
Non-U.S. taxes:   
Current(3)84 290 
Deferred14 24 (267)
State taxes, net of federal benefit:   
Current17 5 4 
Deferred1 1 12 
Total provision (benefit)$150 $123 $(152)


The differences between the U.S. federal statutory income tax rate and our effective tax rate are:

 Years Ended October 31,
 202120202019
 (in millions)
Profit before tax times statutory rate$286 $177 $193 
State income taxes, net of federal benefit18 6 16 
Non-U.S. income taxed at different rates5 (37)(10)
Change in unrecognized tax benefits(84)(8)(11)
Foreign-derived intangible income deduction(35)(9)— 
Extension of the tax incentive in Singapore— — (299)
Excess tax benefits from stock-based compensation(29)(18)(10)
Other, net(11)12 (31)
Provision (benefit) for income taxes$150 $123 $(152)
Effective tax rate11.0 %14.6 %(16.5)%

For 2021, our income tax expense was $150 million with an effective tax rate of 11 percent. For the year ended October 31, 2021, our effective tax rate and the resulting provision for income taxes were impacted by the discrete benefit of $93 million related to the release of tax reserves in various jurisdictions due to audit settlements and the expiration of statutes of limitations. The income taxes for the year ended October 31, 2021 also include the excess tax benefits from stock-based compensation of $29 million.

For 2020, our income tax expense was $123 million with an effective tax rate of 14.6 percent. For the year ended October 31, 2020, our effective tax rate and the resulting provision for income taxes were impacted by foreign income taxed at lower rates.

For 2019, our income tax benefit was $152 million with an effective tax rate of (16.5) percent. For the year ended October 31, 2019, our effective tax rate and the resulting provision for income taxes were significantly impacted by the discrete benefit of $299 million related to the extension of the company’s tax incentive in Singapore.

As part of the business integration of some of our prior acquisitions, we undertook corporate restructurings in the fourth quarter of fiscal year 2019 that involved onshoring certain intangible properties held by our foreign subsidiaries to the United States. These restructurings resulted in a cash tax liability of $231 million. These taxes generate tax attributes that will offset our transition tax liability which is included in other long-term liabilities in our consolidated balance sheet. 

We have negotiated a tax holiday in Singapore. The tax holiday provides a lower rate of taxation on certain classes of income and requires various thresholds of investments and employment or specific types of income. In December 2018, the tax holiday in Singapore was renegotiated and extended through 2027. As a result of the incentive, the impact of the tax holiday decreased income taxes by $35 million, $71 million, and $368 million in 2021, 2020, and 2019, respectively. The benefit of the
tax holiday on net income per share (diluted) was approximately $0.11, $0.23, and $1.16 in 2021, 2020 and 2019, respectively. Of the $1.16 benefit of the tax incentives on net income per share (diluted) in 2019, $0.94 of the benefit relates to one-time items from the extension of the company’s tax incentive in Singapore.

The significant components of deferred tax assets and deferred tax liabilities included on the consolidated balance sheet are:

 Years Ended October 31,
 20212020
 (in millions)
Deferred Tax Assets
Intangibles$72 $153 
Pension benefits and retiree medical benefits— 65 
Employee benefits, other than retirement43 31 
Net operating loss, capital loss, and credit carryforwards191 182 
Share-based compensation22 27 
Lease obligations30 35 
Other42 63 
Deferred tax assets$400 $556 
Tax valuation allowance(120)(132)
Deferred tax assets, net of valuation allowance$280 $424 
Deferred Tax Liabilities
Property, plant and equipment$(11)$(19)
Pension benefits and retiree medical benefits(8)— 
Right-of-use asset(29)(35)
Other(26)(14)
Deferred tax liabilities$(74)$(68)
Net deferred tax assets (liabilities)$206 $356 

Valuation allowances require an assessment of both positive and negative evidence when determining whether it is more likely than not that deferred tax assets are recoverable. Such assessment is required on a jurisdiction by jurisdiction basis. As of October 31, 2021, we continued to maintain a valuation allowance of $120 million until sufficient positive evidence exists to support reversal. The valuation allowance is primarily related to deferred tax assets for the states of California and Colorado, along with the net operating losses in the Netherlands and capital losses in Australia.

At October 31, 2021, we had federal, state and foreign net operating loss carryforwards of approximately $46 million, $461 million and $484 million, respectively. The federal and state net operating loss carryforwards are subject to various limitations under Section 382 of the Internal Revenue Code and applicable state tax laws. If not utilized, the federal and state net operating loss carryforwards will begin to expire in 2022. If not utilized, $15 million of the foreign net operating loss carryforwards will begin to expire in 2022. The remaining $469 million of the foreign net operating losses carry forward indefinitely. At October 31, 2021, we had federal and foreign capital loss carryforwards of $22 million and $127 million, respectively. If not utilized, the federal capital loss carryforwards will expire in 2022. The foreign capital losses carry forward indefinitely. At October 31, 2021, we had state tax credit carryforwards of approximately $82 million. The state tax credits carry forward indefinitely.

The breakdown between long-term deferred tax assets and deferred tax liabilities was as follows:

 October 31,
 20212020
 (in millions)
Long-term deferred tax assets (included within other assets)$309 $380 
Long-term deferred tax liabilities (included within other long-term liabilities)(103)(24)
Total$206 $356 
The breakdown between current and long-term income tax assets and liabilities, excluding deferred tax assets and liabilities, was as follows:
October 31,
20212020
(in millions)
Current income tax assets (included within other current assets)$66 $89 
Long-term income tax assets (included within other assets)6 6 
Current income tax liabilities (included within other accrued liabilities)(47)(63)
Long-term income tax liabilities (included within other long-term liabilities)(241)(323)
Total$(216)$(291)

Uncertain Tax Positions

The aggregate changes in the balances of our gross unrecognized tax benefits including all federal, state and foreign tax jurisdictions are as follows:

202120202019
 (in millions)
Balance, beginning of year$195 $206 $214 
Additions for tax positions related to the current year6 6 7 
Additions for tax positions from prior years4 — 12 
Reductions for tax positions from prior years— — (2)
Settlements with taxing authorities(30)— — 
Statute of limitations expirations(42)(17)(25)
Balance, end of year$133 $195 $206 

As of October 31, 2021, we had $159 million of unrecognized tax benefits, including interest and penalties of which $136 million, if recognized, would affect our effective tax rate. However, approximately $23 million of the unrecognized tax benefits were related to state income tax positions that, if recognized, would be in the form of a deferred tax asset that would likely not affect our effective tax rate due to a valuation allowance.

We recognized tax benefit of $19 million in 2021, tax expense of $8 million and $9 million in 2020 and 2019, respectively, for interest and penalties related to unrecognized tax benefits. Interest and penalties accrued as of October 31, 2021 and 2020 were $26 million and $45 million, respectively.

In the U.S., tax years remain open back to the year 2018 for federal income tax purposes and for significant states. In other major jurisdictions where we conduct business, the tax years generally remain open back to the year 2011.

With these jurisdictions and the U.S., it is reasonably possible that there could be significant changes to our unrecognized tax benefits in the next twelve months due to either the expiration of a statute of limitation or a tax audit settlement which will be partially offset by an anticipated tax liability related to unremitted foreign earnings, where applicable. Given the number of years and numerous matters that remain subject to examination in various tax jurisdictions, management is unable to estimate the range of possible changes to the balance of our unrecognized tax benefits.