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Income Taxes
 12 Months Ended
Dec. 31, 2023
Income Tax Disclosure [Abstract]  
Income Taxes
8.     INCOME TAXES
Our provision for income taxes consisted of the following:
Year Ended December 31,
(in millions)202320222021
U.S. federal:
Current$88.1 81.7 95.1 
Deferred(160.1)(5.8)29.1 
$(72.0)75.9 124.2 
State and Local:
Current$33.4 29.2 34.6 
Deferred(54.6)2.1 11.8 
$(21.2)31.3 46.4 
International:
Current$161.2 136.3 156.0 
Deferred(42.3)(42.7)(62.3)
$118.9 93.6 93.7 
Total$25.7 200.8 264.3 
The U.S. Internal Revenue Code contains two code sections - the Base Erosion Anti-Abuse Tax and Global Intangible Low-Taxed Income Tax - for which we treat any associated income tax as a period cost and record an expense provision for any year we are subject to the taxes. Accordingly, the estimated impacts of these taxes were included in our provision for income taxes in 2023, 2022 and 2021.
Due to the generation of net operating loss carryovers, our current tax expense increased by $69.1 million, $25.6 million and $52.4 million in 2023, 2022 and 2021, respectively, and our deferred tax expense was reduced by a corresponding amount.
Income tax expense differed from the amounts computed by applying the U.S. federal income tax rate of 21% to earnings before provision for income taxes as a result of the following:
Year Ended December 31,
($ in millions)202320222021
Income tax expense at statutory rates$52.9 21.0 %$208.7 21.0 %$256.9 21.0 %
Increase (reduction) in income taxes from:
State and local income taxes, net of federal income tax benefit(17.1)(6.8)26.8 2.7 39.7 3.2 
Nondeductible expenses7.1 2.9 13.9 1.4 17.6 1.4 
International earnings taxed at various rates(58.4)(23.2)(34.7)(3.5)(22.6)(1.8)
U.S. capital loss carryover— — — — (35.2)(2.9)
Valuation allowance41.3 16.4 (4.8)(0.5)34.2 2.8 
Other, net(0.1)(0.1)(9.1)(0.9)(26.3)(2.1)
Total$25.7 10.2 %$200.8 20.2 %$264.3 21.6 %
With respect to international earnings taxed at varying rates, we have operations which constitute a taxable income presence in 93 countries or other taxable jurisdictions outside of the U.S. which are treated as such by the U.S. Internal Revenue Code. Of those countries or other taxable jurisdictions, 70 had income tax rates lower than the combined U.S. federal and state income tax rate in 2023.
In defining "very low tax rate jurisdictions," we consider effective tax rates which applied in 2023 based upon income levels and including national and municipal, state or provincial taxes also based upon income levels, which may cause those effective rates to differ from the maximum national statutory rates for the jurisdictions. We consider jurisdictions with a tax rate of 25% or lower to be very low tax rate jurisdictions, based upon our historical practice. Effective January 1, 2018, the U.S. federal income tax rate was reduced to 21%. However, factoring in the impact of state income taxes, we do not consider the U.S. to be a very low tax rate jurisdiction. With respect to very low tax rate jurisdictions in which we operate, income from Hong Kong (16.5%), Singapore (17%), and Israel (23%) represent the most significant components of the international earnings line item in our effective tax rate reconciliation. In the aggregate, these very low tax rate jurisdictions contributed a large proportion of the difference between the actual income tax provision for international earnings and the equivalent provision at the U.S. federal and state statutory rate in 2023.
Our income (loss) before taxes from domestic (U.S.) and international sources is presented in the following table.
Year Ended December 31,
(in millions)202320222021
Domestic$(175.5)447.9 798.9 
International427.4 546.3 424.7 
Total$251.9 994.2 1,223.6 
The tax effects of temporary differences that give rise to significant portions of the deferred tax assets and deferred tax liabilities are presented below.
December 31,
(in millions)20232022
Deferred tax assets attributable to:
Accrued expenses$511.3 393.6 
U.S. federal and state loss and credit carryovers55.1 52.5 
Allowances for uncollectible accounts37.6 33.9 
International loss carryovers313.0 237.3 
Investments1.6 — 
Pension liabilities27.7 19.8 
Deferred tax assets946.3 737.1 
Less: valuation allowances(172.7)(120.8)
Net deferred tax assets$773.6 616.3 
Deferred tax liabilities attributable to:
Property and equipment$24.8 23.6 
Intangible assets277.7 325.6 
Income deferred for tax purposes11.4 7.5 
Investments— 72.6 
Other7.1 1.4 
Deferred tax liabilities$321.0 430.7 
Net deferred taxes$452.6 185.6 
The increase in gross deferred tax assets in 2023 was primarily the result of (a) deferral of tax deductions for compensation accruals and (b) revaluations of investments which are not yet deductible for tax purposes. The increase in valuation reserves was primarily the result of additional reserves established against deferred tax assets related to certain expense accruals.
We have not provided a deferred tax liability on the unremitted foreign earnings of international subsidiaries because it is our intent to permanently reinvest such earnings outside of the U.S. If repatriation of all such earnings were to occur, we would incur withholding taxes, dividend distribution taxes and potentially an amount of gain taxation which is not presently determinable.
As of December 31, 2023, we had an available U.S. federal net operating loss ("NOL") carryover of $53.5 million from acquired companies, for which we have established a full valuation allowance due to significant statutory limitations on its usage, and which will begin to expire in 2028. We have U.S. state NOL carryovers with a tax effect of $20.1 million, which expire at various dates through 2043, and international NOL carryovers of $1,233.8 million, which generally do not have expiration dates. The change in deferred tax balances for NOL carryovers from 2022 to 2023 included increases from current year losses and decreases from current year estimated utilization.
As of December 31, 2023, we believe it is more-likely-than-not the net deferred tax assets of $452.6 million will be realized based upon our estimates of future income and the consideration of net operating losses, earnings trends and tax planning strategies. Valuation allowances have been provided with regard to the tax benefit of certain international NOL carryovers, for which we have concluded recognition is not yet appropriate. In 2023, we reduced valuation allowances by $5.4 million on some jurisdictions' NOLs due to the utilization or expiration of those losses; and we increased valuation allowances by $54.0 million for other jurisdictions based upon circumstances that caused us to establish or continue to provide valuation allowances on current or prior-year losses (including acquired NOL carryovers) in addition to those provided in prior years. The remaining movement in valuation allowances comparing December 31, 2023 to December 31, 2022 was attributable to the effect of changes in foreign currency exchange rates.
As of December 31, 2023, our net current payable for income tax was $154.3 million, consisting of a current receivable of $215.8 million and current payable of $370.1 million, and our net noncurrent liability was $87.6 million, entirely a noncurrent payable. As of December 31, 2022, our net current receivable for income tax was $1.0 million, consisting of a current receivable of $215.2 million and a current payable of $214.2 million, and our net noncurrent liability was $114.7 million, entirely a noncurrent payable. The current receivables, current payables, and noncurrent payables are included in Notes and other receivables, Accounts payable and accrued liabilities, and Other liabilities, respectively, on our Consolidated Balance Sheets.
We file income tax returns in the U.S. (including 46 states, 25 cities, the District of Columbia and Puerto Rico), the United Kingdom (including England, Scotland and Wales), Australia, Germany, The People's Republic of China (including Hong Kong and Macau), France, Japan, Singapore, India, the Netherlands, Spain and 78 other countries. Generally, our open tax years include those from 2020 to the present, although reviews of taxing authorities for more recent years have been completed or are in process in a number of jurisdictions.
As of December 31, 2023, we were under examination in Germany, Nigeria, Pakistan, Egypt, Oman, Sweden, the Netherlands, Turkey, Indonesia, India, Mauritius, the Philippines, Hong Kong, Sri Lanka and Thailand. In the U.S., we were under examination by the Internal Revenue Service for the Transition Tax reported in our 2018 federal income tax return; as well as in the states of Illinois, Massachusetts, New York City and Washington D.C.
A reconciliation of the beginning and ending amount of unrecognized tax benefits is presented in the following table.
(in millions)20232022
Balance as of January 1,
$75.1 79.3 
Additions based on tax positions related to the current year2.9 3.6 
Decrease related to tax positions of prior years(6.8)(5.6)
Settlements with taxing authorities— (2.2)
Balance as of December 31,
$71.2 75.1 
We believe it is reasonably possible that matters for which we have recorded $47.7 million of unrecognized tax benefits as of December 31, 2023, will be resolved during 2024. The recognition of tax benefits, and other changes to the amounts of our unrecognized tax benefits, may occur as the result of ongoing operations, the outcomes of audits or other examinations by tax authorities, or the passing of statutes of limitations. We do not expect changes to our unrecognized tax benefits to have a
significant impact on net income, the financial position, or the cash flows of JLL. We do not believe we have material tax positions for which the ultimate deductibility is highly certain, but there is uncertainty about the timing of such deductibility.
We recognize interest accrued and penalties, if any, in Income tax provision on our Consolidated Statements of Comprehensive Income. During the years ended December 31, 2023, 2022 and 2021, the amount of interest expense and penalties was not material. In addition, the amount of accrued interest related to income taxes was not material as of December 31, 2023 and 2022