INCOME TAXES

Detail of the provision for income taxes from continuing operations consists of the following:



						in millions
	2015		2014			2013
Federal	$	564	$	325		$	341
State	89		67			38
Foreign	44		4			30
	$	697	$	396		$	409

Current	$	659	$	501		$	421
Deferred	38		(105		)	(12		)
	$	697	$	396		$	409

The reasons for the difference between the statutory federal income tax rate and our effective income tax rate from continuing operations are as follows:



	2015		2014		2013
Federal income tax rate	35.0	%	35.0	%	35.0	%
State income taxes	3.1		2.8		2.4
Unrecognized tax benefits, net	(1.8	)	(4.7	)	(0.2	)
Domestic production deduction	(3.7	)	(4.0	)	(3.2	)
Foreign rate differences and valuation allowances	3.8		2.8		0.3
Other	(0.1	)	(0.3	)	(1.7	)
	36.3	%	31.6	%	32.6	%

During fiscal 2015, the domestic production deduction and changes in unrecognized tax benefits decreased tax expense by $72 million and $34 million, respectively, and state tax expense, net of federal tax benefit, was $59 million. Additionally, foreign rate differences, mostly driven by the China impairment, unfavorably impacted tax expense by $73 million. The sale of the Mexico and Brazil operations and related repatriation of proceeds did not have a significant impact on the effective income tax rate.

During fiscal 2014, the domestic production deduction and the decrease in unrecognized tax benefits decreased tax expense by $50 million and $58 million, respectively.

During fiscal 2013, the domestic production deduction and estimated general business credits decreased tax expense by $40 million and $17 million, respectively.

Approximately $1,908 million, $1,270 million, and $1,204 million of income from continuing operations before income taxes for fiscal 2015, 2014 and 2013, respectively, were from our domestic operations based in the United States.

We recognize deferred income taxes for the future tax consequences attributable to differences between the financial statement carrying amounts of existing assets and liabilities and their respective tax bases. Deferred tax assets and liabilities are measured using tax rates expected to apply to taxable income in the years in which those temporary differences are expected to be recovered or settled.

The tax effects of major items recorded as deferred tax assets and liabilities as of October 3, 2015, and September 27, 2014, are as follows:



									in millions
	2015					2014
	Deferred Tax					Deferred Tax
	Assets			Liabilities		Assets			Liabilities
Property, plant and equipment	$	—		$	783	$	—		$	732
Intangible assets	—			2,000		—			2,031
Accrued expenses	439			—		474			—
Net operating loss and other carryforwards	97			—		96			—
Other	122			238		125			269
	$	658		$	3,021	$	695		$	3,032
Valuation allowance	$	(68	)			$	(51	)
Net deferred tax liability				$	2,431				$	2,388

We record deferred tax amounts in Other current assets, Other Assets, Other current liabilities and Deferred Income Taxes in the Consolidated Balance Sheets.

At October 3, 2015, our gross state tax net operating loss carryforwards approximated $938 million and expire in fiscal years 2016 through 2035. Gross foreign net operating loss carryforwards approximated $29 million and expire in fiscal years 2016 through 2021. We also have tax credit carryforwards of approximately $46 million that expire in fiscal years 2016 through 2035.

We have accumulated undistributed earnings of foreign subsidiaries aggregating approximately $139 million and $403 million at October 3, 2015, and September 27, 2014, respectively. In fiscal 2015, the Company completed the sales of the Mexico and Brazil operations and repatriated the related net proceeds resulting in a significant decrease in the balance of accumulated undistributed earnings. The accumulated undistributed earnings at October 3, 2015 are expected to be indefinitely reinvested outside of the United States. If those earnings were distributed in the form of dividends or otherwise, we could be subject to federal income taxes (subject to an adjustment for foreign tax credits), state income taxes and withholding taxes payable to the various foreign countries. Due to the uncertainty of the manner in which the undistributed earnings would be brought back to the United States, the tax laws in effect at that time, as well as the availability of the Company to claim foreign tax credits, it is not currently practicable to estimate the tax liability that might be payable on the repatriation of these foreign earnings.

The following table summarizes the activity related to our gross unrecognized tax benefits at October 3, 2015, September 27, 2014, and September 28, 2013:



							in millions
	2015			2014			2013
Balance as of the beginning of the year	$	272		$	175		$	168
Increases related to current year tax positions	78			11			3
Increases related to prior year tax positions	11			17			15
Change related to Hillshire Brands balances	—			136			—
Reductions related to prior year tax positions	(18		)	(20		)	(6		)
Reductions related to settlements	—			(1		)	(2		)
Reductions related to expirations of statute of limitations	(37		)	(46		)	(3		)
Balance as of the end of the year	$	306		$	272		$	175

The amount of unrecognized tax benefits, if recognized, that would impact our effective tax rate was $244 million and $241 million at October 3, 2015, and September 27, 2014, respectively. We classify interest and penalties on unrecognized tax benefits as income tax expense. At October 3, 2015, and September 27, 2014, before tax benefits, we had $46 million and $54 million, respectively, of accrued interest and penalties on unrecognized tax benefits.

As of October 3, 2015, we are subject to income tax examinations for United States federal income taxes for fiscal years 2011 through 2014. We are also subject to income tax examinations by major state and foreign jurisdictions for fiscal years 2005 through 2014 and 2002 through 2014, respectively. We estimate that during the next twelve months it is reasonably possible that unrecognized tax benefits could decrease by as much as $14 million primarily due to expiration of statutes in various jurisdictions.