PROVISION FOR INCOME TAXES

Components of earnings from continuing operations before income taxes and the provision (benefit) for U.S. and other income taxes from continuing operations follow:



	For years ended December 31,
(Dollars in millions)	2016			2015			2014
Earnings from continuing operations before income taxes
United States	$	422		$	618		$	627
Outside the United States	627			511			363
Total	$	1,049		$	1,129		$	990
Provision (benefit) for income taxes on earnings from continuing operations
United States Federal
Current	$	(80	)	$	87		$	64
Deferred	214			119			135
Outside the United States
Current	91			59			66
Deferred	(18		)	16			(35		)
State and other
Current	2			22			6
Deferred	(19		)	(28		)	(1		)
Total	$	190		$	275		$	235

The following represents the deferred tax charge (benefit) recorded as a component of accumulated other comprehensive loss in stockholders' equity:



	For years ended December 31,
(Dollars in millions)	2016		2015		2014
Defined benefit pension and other postretirement benefit plans	$	21	$	42	$	(11	)
Cumulative translation adjustment	—		—		—
Derivatives and hedging	105		21		(141		)
Total	$	126	$	63	$	(152	)

Total income tax expense (benefit) included in the consolidated financial statements was composed of the following:



	For years ended December 31,
(Dollars in millions)	2016		2015		2014
Continuing operations	$	190	$	275	$	235
Discontinued operations	—		—		2
Other comprehensive income	126		63		(152		)
Total	$	316	$	338	$	85

Differences between the provision for income taxes on earnings from continuing operations and income taxes computed using the U.S. Federal statutory income tax rate follow:



	For years ended December 31,
(Dollars in millions)	2016			2015			2014
Amount computed using the statutory rate	$	366		$	393		$	345
State income taxes, net	(18		)	(3		)	4
Foreign rate variance	(121		)	(93		)	(105		)
Domestic manufacturing deduction	(7		)	(12		)	(6		)
Change in reserves for tax contingencies	—			(7		)	(6		)
General business credits	(20		)	(15		)	(8		)
U.S. tax on foreign earnings	25			7			5
Other	(35		)	5			6
Provision for income taxes	$	190		$	275		$	235

Effective income tax rate	18		%	24		%	24		%

The 2016 effective tax rate was lower than 2015 due to a benefit in the foreign rate variance as a result of higher earnings in foreign jurisdictions partially offset by a reduction in the U.S. federal tax manufacturing deduction due to a decrease in domestic taxable income. The 2016 effective tax rate included a tax benefit of $16 million related to foreign tax credits as a result of the amendment of prior year income tax returns, a $16 million one-time benefit for the restoration of tax basis for which depreciation deductions were previously limited, and a $9 million tax benefit primarily due to adjustments to the tax provision to reflect the finalization of 2014 foreign income tax returns.

The 2015 effective tax rate reflected a benefit from both the U.S. federal tax manufacturing deduction, due to an increase in domestic taxable income, and increased U.S. federal tax credits compared to 2014. This was offset by a reduction in the foreign rate variance as a result of an unfavorable shift in foreign income to higher tax jurisdictions and limited benefit from the asset impairment of the Workington, UK acetate tow manufacturing facility. Both years reflect a benefit from the extension of favorable U.S. federal tax provisions, which resulted in a net benefit of approximately $15 million primarily related to R&D credits and deferral of certain earnings of foreign subsidiaries from U.S. income taxes.

The significant components of deferred tax assets and liabilities follow:



	December 31,
(Dollars in millions)	2016			2015
Deferred tax assets
Post-employment obligations	$	378		$	471
Net operating loss carryforwards	337			349
Tax credit carryforwards	248			276
Environmental reserves	119			122
Unrealized derivative loss	50			162
Other	186			193
Total deferred tax assets	1,318			1,573
Less valuation allowance	278			254
Deferred tax assets less valuation allowance	$	1,040		$	1,319
Deferred tax liabilities
Property, plant, and equipment	$	(1,237	)	$	(1,176	)
Intangible assets	(847		)	(902		)
Other	(128		)	(142		)
Total deferred tax liabilities	$	(2,212	)	$	(2,220	)
Net deferred tax liabilities	$	(1,172	)	$	(901	)
As recorded in the Consolidated Statements of Financial Position:
Other noncurrent assets	$	34		$	27
Deferred income tax liabilities	(1,206		)	(928		)
Net deferred tax liabilities	$	(1,172	)	$	(901	)

Unremitted earnings of subsidiaries outside the United States, considered to be reinvested indefinitely, totaled approximately $2.1 billion at December 31, 2016. It is not practicable to determine the deferred tax liability for temporary differences related to those unremitted earnings.

For certain consolidated foreign subsidiaries, income and losses directly flow through to taxable income in the United States. These entities are also subject to taxation in the foreign tax jurisdictions. Net operating loss carryforwards exist to offset future taxable income in foreign tax jurisdictions and valuation allowances are provided to reduce deferred related tax assets if it is more likely than not that this benefit will not be realized. Changes in the estimated realizable amount of deferred tax assets associated with net operating losses for these entities could result in changes in the deferred tax asset valuation allowance in the foreign tax jurisdiction. At the same time, because these entities are also subject to tax in the United States, a deferred tax liability for the expected future taxable income will be established concurrently. Therefore, the impact of any reversal of valuation allowances on consolidated income tax expense will be only to the extent that there are differences between the United States statutory tax rate and the tax rate in the foreign jurisdiction. A valuation allowance of $18 million at December 31, 2016 has been provided against the deferred tax asset resulting from these operating loss carryforwards.

At December 31, 2016, foreign net operating loss carryforwards totaled $914 million. Of this total, $49 million will expire in 1 to 20 years and $865 million have no expiration date. A valuation allowance of approximately $209 million has been provided against such net operating loss carryforwards.

At December 31, 2016, federal net operating loss carryforwards of $20 million were available to offset future taxable income, which expire from 2027 to 2030. At December 31, 2016, foreign tax credit carryforwards of approximately $140 million were available to reduce possible future U.S. income taxes and which expire from 2017 to 2021.

A partial valuation allowance of $45 million has been provided for Solutia's state net operating loss carryforwards. The valuation allowance will be retained until there is sufficient positive evidence to conclude that it is more likely than not that the deferred tax assets will be realized or the related statute expires.

As a result of the Solutia acquisition transaction, Solutia realized a change of ownership for purposes of Section 382 of the Internal Revenue Code. Management does not currently expect this change to significantly limit the Company's ability to utilize Solutia's U.S. foreign tax credit carryforwards estimated to be approximately $140 million at December 31, 2016.

Amounts due to and from tax authorities as recorded in the Consolidated Statements of Financial Position:



	December 31,
(Dollars in millions)	2016		2015
Miscellaneous receivables	$	235	$	92

Payables and other current liabilities	$	56	$	33
Other long-term liabilities	60		32
Total income taxes payable	$	116	$	65

A reconciliation of the beginning and ending amounts of unrecognized tax benefits is as follows:



(Dollars in millions)	2016			2015				2014
Balance at January 1	$	125		$	117			$	51
Adjustments based on tax positions related to current year	(7		)	(12		)	⁽¹⁾	—
Additions based on acquisitions	—			27				72
Lapse of statute of limitations	(4		)	(7		)		(6		)
Settlements	—			—				—
Balance at December 31	$	114		$	125			$	117


⁽¹⁾	Revised from Note 8, "Provision For Income Taxes" to the Company's 2015 Annual Report on Form 10-K, which incorrectly reported Additions based on tax positions related to current year as zero.

As of December 31, 2016, 2015, and 2014, $114 million, $125 million, and $117 million, respectively, of unrecognized tax benefits would, if recognized, impact the Company's effective tax rate.

Interest, net of tax, related to unrecognized tax benefits is recorded as a component of income tax expense. As of January 1, 2016, the Company had accrued a liability of $4 million for interest, net of tax, and had accrued $1 million for estimated tax penalties, net of tax benefit. During 2016, the Company recognized $1 million of expense for interest, net of tax, and no penalties associated with unrecognized tax benefits, offset by $1 million of income for interest, net of tax, and no penalties, net of tax, associated with the expiration of the statute of limitations. At December 31, 2016, the Company had accrued balances of $4 million for interest, net of tax benefit, and $1 million for penalties, net of tax benefit.

As of January 1, 2015, the Company had accrued a liability of $4 million for interest, net of tax, and had $3 million for tax penalties, net of tax benefit. During 2015, the Company recognized $2 million of expense for interest, net of tax, and no penalties associated with unrecognized tax benefits, offset by $2 million of income for interest, net of tax, and $2 million of penalties, net of tax, associated with the expiration of the statute of limitations. At December 31, 2015, the Company had accrued balances of $4 million for interest, net of tax benefit, and $1 million for penalties, net of tax benefit.

As of January 1, 2014, the Company had accrued a liability of $4 million for interest, net of tax, and had $3 million for tax penalties, net of tax benefit. During 2014, the Company recognized $1 million of expense for interest, net of tax, and no penalties associated with unrecognized tax benefits, offset by $1 million of income for interest, net of tax, associated with the expiration of the statute of limitations. At December 31, 2014, the Company had accrued balances of $4 million for interest, net of tax benefit, and $3 million for penalties, net of tax benefit.

The Company files income tax returns in the United States and various state and foreign jurisdictions. The Company is no longer subject to U.S. Federal income tax examinations by tax authorities for years before 2011 and 2002 for Eastman and Solutia, respectively. With few exceptions, Eastman is no longer subject to state and local income tax examinations by tax authorities for years before 2010. Solutia and related subsidiaries are no longer subject to state and local income tax examinations for years before 2000. With few exceptions, the Company is no longer subject to foreign income tax examinations by tax authorities for tax years before 2007.

It is reasonably possible that, within the next twelve months, as a result of the resolution of federal, state, and foreign examinations and appeals, and the expiration of various statutes of limitation, unrecognized tax benefits could decrease by up to $20 million.