INCOME TAXES

12 Months Ended

Dec. 31, 2020


					(In Millions)
	2020		2019		2018
Income from continuing operations before income taxes:
U.S.	$	892	$	684	$	670
Foreign	239		230		237
	$	1,131	$	914	$	907
Income tax expense:
Currently payable:
U.S. Federal	$	170	$	155	$	115
State and local	33		46		29
Foreign	69		70		74
Deferred:
U.S. Federal	(9)		(23)		12
State and local	11		(15)		—
Foreign	(5)		(3)		(9)
	$	269	$	230	$	221
Deferred tax assets at December 31:
Receivables	$	9	$	7
Inventories	17		15
Other assets, including stock-based compensation	17		15
Accrued liabilities	82		48
Noncurrent operating lease liabilities	35		39
Other long-term liabilities	96		137
Net operating loss carryforward	56		63
Tax credit carryforward	9		9
	321		333
Valuation allowance	(35)		(38)
	286		295
Deferred tax liabilities at December 31:
Property and equipment	67		73
Operating lease right-of-use assets	39		42
Intangibles	74		71
Investment in foreign subsidiaries	10		10
Other investments	3		—
Other	4		22
	197		218
Net deferred tax asset at December 31	$	89	$	77

The net deferred tax asset consisted of net deferred tax assets (included in other assets) of $109 million and $99 million, and net deferred tax liabilities (included in other liabilities) of $20 million and $22 million, at December 31, 2020 and 2019, respectively.

We continue to maintain a valuation allowance on certain state and foreign deferred tax assets as of December 31, 2020. Should we determine that we would not be able to realize our remaining deferred tax assets, or the deferred tax assets that currently have a valuation allowance become realizable in these jurisdictions in the future, an adjustment to the valuation allowance would be recorded in the period such determination is made.

S. INCOME TAXES (Continued)

The current portion of the state and local income tax includes a $9 million, $8 million and $8 million tax benefit from the reversal of an accrual for uncertain tax positions resulting primarily from the expiration of applicable statutes of limitations in 2020, 2019 and 2018, respectively. The deferred portion of the state and local taxes includes a $1 million tax benefit in 2019 and 2018, resulting from changes in valuation allowances against state and local deferred tax assets. The deferred portion of the foreign taxes includes a $5 million, $4 million and $2 million tax benefit in 2020, 2019 and 2018, respectively, from a change in the valuation allowances against foreign deferred tax assets.

Our capital allocation strategy includes reinvesting in our business, balancing share repurchases with potential acquisitions and maintaining an appropriate dividend. In order to provide greater flexibility in the execution of our capital allocation strategy, we may repatriate earnings from certain foreign subsidiaries. Our deferred tax balance on investment in foreign subsidiaries reflects the impact of all taxable temporary differences, including those related to substantially all undistributed foreign earnings, except those that are legally restricted, and consists primarily of foreign withholding taxes.

Of the $65 million and $72 million deferred tax assets related to the net operating loss and tax credit carryforwards at December 31, 2020 and 2019, respectively, $35 million and $44 million, respectively, will expire between 2021 and 2036 and $30 million and $28 million, respectively, have no expiration.

A reconciliation of the U.S. Federal statutory tax rate to the income tax expense on income from continuing operations before income taxes was as follows:


	2020		2019		2018
U.S. Federal statutory tax rate	21	%	21	%	21	%
State and local taxes, net of U.S. Federal tax benefit	3		3		3
Higher taxes on foreign earnings	1		2		2
U.S. and foreign taxes on distributed and undistributed foreign earnings	—		1		1
Stock-based compensation	(1)		(1)		(2)


Other, net	—		(1)		(1)
Effective tax rate	24	%	25	%	24	%

Income taxes paid were $442 million, $384 million and $231 million in 2020, 2019 and 2018, respectively.

S. INCOME TAXES (Concluded)

A reconciliation of the beginning and ending liability for uncertain tax positions, including related interest and penalties, is as follows, in millions:


	Uncertain Tax Positions		Interest and Penalties		Total
Balance at January 1, 2019	$	58	$	9	$	67
Current year tax positions:
Additions	14		—		14
Reductions	(1)		—		(1)
Prior year tax positions:
Additions	1		—		1

Lapse of applicable statute of limitations	(9)		—		(9)
Interest and penalties recognized in income tax expense	—		1		1
Balance at December 31, 2019	$	63	$	10	$	73
Current year tax positions:
Additions	22		—		22
Reductions	(2)		—		(2)
Prior year tax positions:
Additions	2		—		2
Reductions	(2)		—		(2)
Lapse of applicable statute of limitations	(9)		—		(9)

Balance at December 31, 2020	$	74	$	10	$	84

If recognized, $58 million and $50 million of the liability for uncertain tax positions at December 31, 2020 and 2019, respectively, net of any U.S. Federal tax benefit, would impact our effective tax rate.

Of the $84 million and $73 million total liability for uncertain tax positions (including related interest and penalties) at December 31, 2020 and 2019, respectively, $81 million and $68 million are recorded in other liabilities, respectively, and $3 million and $5 million are recorded as a net offset to other assets, respectively.

We file income tax returns in the U.S. Federal jurisdiction, and various local, state and foreign jurisdictions. We continue to participate in the Compliance Assurance Process ("CAP"). CAP is a real-time audit of the U.S. Federal income tax return that allows the Internal Revenue Service ("IRS"), working in conjunction with us, to determine tax return compliance with the U.S. Federal tax law prior to filing the return. This program provides us with greater certainty about our tax liability for a given year within months, rather than years, of filing our annual tax return and greatly reduces the need for recording a liability for U.S. Federal uncertain tax positions. The IRS has completed their examination of our consolidated U.S. Federal tax returns through 2019. With few exceptions, we are no longer subject to state or foreign income tax examinations on filed returns for years before 2016.

As a result of tax audit closings, settlements and the expiration of applicable statutes of limitation in various jurisdictions within the next 12 months, we anticipate that it is reasonably possible the liability for uncertain tax positions could be reduced by approximately $9 million.