INCOME TAXES

U.S. and foreign earnings from continuing operations before income taxes are as follows:



	Years Ended December 31,
	2014		2013		2012
	(In thousands)
U.S.	$	174,792	$	331,520	$	214,675
Foreign	95,137		84,781		74,387
Total	$	269,929	$	416,301	$	289,062

The components of the (benefit) provision for income taxes attributable to continuing operations are as follows:



	Years Ended December 31,
	2014			2013			2012
	(In thousands)
Current income tax (benefit) provision :
Federal	$	(45,842	)	$	115,250		$	56,439
State	(14,787		)	13,946			9,204
Foreign	19,132			14,402			16,496
Current income tax (benefit) provision	(41,497		)	143,598			82,139
Deferred income tax provision (benefit):
Federal	74,255			(821		)	40,414
State	3,090			(2,117		)	1,978
Foreign	(476		)	(6,158		)	(5,316		)
Deferred income tax provision (benefit)	76,869			(9,096		)	37,076
Income tax provision	$	35,372		$	134,502		$	119,215

The current income tax payable was reduced by $45.0 million, $32.9 million and $57.1 million for the years ended December 31, 2014, 2013 and 2012, respectively, for excess tax deductions attributable to stock-based compensation. The related income tax benefits are recorded as increases to additional paid-in capital.

Income taxes receivable (payable) and deferred tax assets (liabilities) are included in the following captions in the accompanying consolidated balance sheet at December 31, 2014 and 2013:



	December 31,
	2014			2013
	(In thousands)
Income taxes receivable (payable):
Other current assets	$	4,505		$	12,242
Other non-current assets	1,478			19,217
Accrued expenses and other current liabilities	(41,157		)	(16,159		)
Income taxes payable	(32,635		)	(416,384		)
Net income taxes payable	$	(67,809	)	$	(401,084	)

Deferred tax assets (liabilities):
Other current assets	$	17,993		$	34,381
Other non-current assets	1,380			26
Accrued expenses and other current liabilities	(255		)	(255		)
Deferred income taxes	(409,529		)	(320,748		)
Net deferred tax liabilities	$	(390,411	)	$	(286,596	)

The tax effects of cumulative temporary differences that give rise to significant deferred tax assets and deferred tax liabilities are presented below. The valuation allowance relates to deferred tax assets for which it is more likely than not that the tax benefit will not be realized.



	December 31,
	2014			2013
	(In thousands)
Deferred tax assets:
Accrued expenses	$	34,654		$	28,005
Net operating loss carryforwards	55,579			52,336
Tax credit carryforwards	13,585			6,138
Stock-based compensation	69,342			69,101
Income tax reserves, including related interest	2,247			62,852
Cost method investments	27,581			2,383
Equity method investments	14,998			13,584
Other	10,075			10,212
Total deferred tax assets	228,061			244,611
Less valuation allowance	(98,350		)	(62,353		)
Net deferred tax assets	129,711			182,258
Deferred tax liabilities:
Investment in subsidiaries	(378,769		)	(377,483		)
Intangible and other assets	(115,470		)	(69,530		)
Other	(25,883		)	(21,841		)
Total deferred tax liabilities	(520,122		)	(468,854		)
Net deferred tax liabilities	$	(390,411	)	$	(286,596	)

At December 31, 2014, the Company has federal and state net operating losses ("NOLs") of $61.5 million and $82.6 million, respectively. If not utilized, the federal NOLs will expire at various times between 2023 and 2034, and the state NOLs will expire at various times between 2015 and 2034. Utilization of federal NOLs will be subject to limitations under Section 382 of the Internal Revenue Code of 1986, as amended. In addition, utilization of certain state NOLs may be subject to limitations under state laws similar to Section 382 of the Internal Revenue Code of 1986. At December 31, 2014, the Company has foreign NOLs of $107.5 million available to offset future income. Of these foreign NOLs, $98.1 million can be carried forward indefinitely and $9.3 million will expire at various times between 2015 and 2034. During 2014, the Company recognized tax benefits related to NOLs of $0.8 million. At December 31, 2014, the Company has $5.1 million of state capital losses. If not utilized, the state capital losses will expire between 2015 and 2017. Utilization of capital losses will be limited to the Company's ability to generate future capital gains.

At December 31, 2014, the Company has tax credit carryforwards of $19.0 million. Of this amount, $5.2 million relates to federal credits for foreign taxes, $8.2 million relates to state tax credits for research activities, and $5.6 million relates to various state and local tax credits. Of these credit carryforwards, $10.0 million can be carried forward indefinitely and $9.0 million will expire within ten years.

During 2014, the Company's valuation allowance increased by $36.0 million primarily due to increases in unrealized capital losses, net operating losses, and tax credits. At December 31, 2014, the Company has a valuation allowance of $98.3 million related to the portion of tax loss carryforwards and other items for which it is more likely than not that the tax benefit will not be realized.

A reconciliation of the income tax provision to the amounts computed by applying the statutory federal income tax rate to earnings from continuing operations before income taxes is shown as follows:



	Years Ended December 31,
	2014			2013			2012
	(In thousands)
Income tax provision at the federal statutory rate of 35%	$	94,475		$	145,705		$	101,172
Change in tax reserves, net	(86,151		)	1,791			17,703
Foreign income taxed at a different statutory tax rate	(8,943		)	(17,428		)	(16,240		)
State income taxes, net of effect of federal tax benefit	7,240			7,469			7,650
Non-deductible goodwill associated with the sale of Urbanspoon	6,982			—			—
Non-deductible impairments for certain cost method investments	23,310			1,756			226
Other, net	(1,541		)	(4,791		)	8,704
Income tax provision	$	35,372		$	134,502		$	119,215

No income taxes have been provided on indefinitely reinvested earnings of certain foreign subsidiaries aggregating $605.7 million at December 31, 2014. The amount of the unrecognized deferred income tax liability with respect to such earnings is $141.5 million.

A reconciliation of the beginning and ending amount of unrecognized tax benefits, excluding interest, is as follows:



	December 31,
	2014			2013			2012
	(In thousands)
Balance at January 1	$	275,813		$	379,281		$	351,561
Additions based on tax positions related to the current year	2,159			2,887			6,278
Additions for tax positions of prior years	1,622			3,189			45,287
Reductions for tax positions of prior years	(5,611		)	(17,116		)	(17,545		)
Settlements	(5,092		)	(78,954		)	(5,349		)
Expiration of applicable statutes of limitations	(238,505		)	(13,474		)	(951		)
Balance at December 31	$	30,386		$	275,813		$	379,281

The Company recognizes interest and, if applicable, penalties related to unrecognized tax benefits in the income tax provision. Included in the income tax provision for continuing operations for the years ended December 31, 2014, 2013 and 2012 is a $58.5 million benefit, $4.8 million expense and $5.2 million expense, respectively, net of related deferred taxes of $35.3 million, $2.8 million and $3.1 million, respectively, for interest on unrecognized tax benefits. Included in the income tax provision for discontinued operations for the years ended December 31, 2014, 2013 and 2012 is a $19.7 million benefit, $1.4 million expense and $2.8 million benefit, respectively, net of related deferred taxes of $11.7 million, $0.8 million and $1.7 million, respectively, for interest on unrecognized tax benefits. At December 31, 2014 and 2013, the Company has accrued $2.8 million and $133.0 million, respectively, for the payment of interest. At December 31, 2014 and 2013, the Company has accrued $2.9 million and $5.1 million, respectively, for penalties.

The Company is routinely under audit by federal, state, local and foreign authorities in the area of income tax. These audits include questioning the timing and the amount of income and deductions and the allocation of income and deductions among various tax jurisdictions. The Internal Revenue Service is currently auditing the Company’s federal income tax returns for the years ended December 31, 2010 through 2012. Various other jurisdictions are open to examination for various tax years beginning with 2006. Income taxes payable include reserves considered sufficient to pay assessments that may result from examination of prior year tax returns. Changes to reserves from period to period and differences between amounts paid, if any, upon resolution of audits and amounts previously provided may be material. Differences between the reserves for income tax contingencies and the amounts owed by the Company are recorded in the period they become known.

The statutes of limitations for federal income taxes for the years 2001 through 2009 expired on July 1, 2014. As a result, previously unrecognized tax benefits, including interest, totaling $374.8 million were recognized in the third quarter of 2014. The income tax benefit to continuing operations and discontinued operations was $88.2 million and $175.7 million, respectively. The remaining amount of $110.9 million impacted various balance sheet accounts, primarily non-current deferred tax assets, which were reduced by $100.1 million. At December 31, 2014 and 2013, unrecognized tax benefits, including interest, are $33.2 million and $408.8 million, respectively. If unrecognized tax benefits at December 31, 2014 are subsequently recognized, $30.5 million, net of related deferred tax assets and interest, would reduce income tax provision for continuing operations. The Company believes that it is reasonably possible that its unrecognized tax benefits could decrease by $8.8 million within twelve months of the current reporting date primarily due to expirations of statutes of limitations; $8.4 million of which would reduce the income tax provision for continuing operations.