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Income Taxes (Tables)

12 Months Ended

Dec. 31, 2015

Income Taxes [Line Items]

Provision for (Benefit From) Income Taxes

The provision for (benefit from) income taxes consists of the following:

		Year Ended December 31,
		2015				2014				2013
Current
	Federal	$	(32	)		$	(1	)		$	(4	)
	State	3				4				12
	Foreign	40				79				36
	Current income tax provision	11				82				44
Deferred
	Federal	45				89				28
	State	(1		)		2				8
	Foreign	14				(26		)		1
	Deferred income tax provision	58				65				37
Provision for income taxes		$	69			$	147			$	81

Pretax Income (Loss) for Domestic and Foreign Operations

Pretax income for domestic and foreign operations consists of the following:

	Year Ended December 31,
	2015				2014				2013
United States (a)	$	258			$	248			$	4
Foreign	124				144				93
Pretax income	$	382			$	392			$	97

__________

^(a)   For the years ended December 31, 2015, 2014 and 2013, includes corporate debt extinguishment costs of $23 million, $56 million and $147 million, respectively.

Deferred Income Tax Assets and Liabilities

Deferred income tax assets and liabilities are comprised of the following:

		As of December 31,
		2015				2014
Deferred income tax assets:
	Net tax loss carryforwards	$	1,567			$	1,483
	Accrued liabilities and deferred revenue	276				297
	Tax credits	76				75
	Depreciation and amortization	13				23
	Acquisition and integration-related liabilities	13				8
	Provision for doubtful accounts	7				7
	Unrealized hedge loss	—				1
	Other	46				57
	Valuation allowance (a)	(351		)		(319		)
Deferred income tax assets		1,647				1,632
Deferred income tax liabilities:
	Depreciation and amortization	123				96
	Prepaid expenses	29				21
	Other	7				4
Deferred income tax liabilities		159				121
Deferred income tax assets, net		$	1,488			$	1,511

__________

^(a)  The valuation allowance of $351 million at December 31, 2015 relates to tax loss carryforwards, foreign tax credits and certain deferred tax assets of $267 million, $53 million and $31 million, respectively. The valuation allowance will be reduced when and if the Company determines it is more likely than not that the related deferred income tax assets will be realized. The valuation allowance of $319 million at December 31, 2014 relates to tax loss carryforwards, foreign tax credits and certain deferred tax assets of $249 million, $46 million and $24 million, respectively.

Reconciliation of U.S Federal Income Tax Statutory Rate and Effective Income Tax Rate

The reconciliation between the U.S. federal income tax statutory rate and the Company’s effective income tax rate is as follows:

		Year Ended December 31,
		2015			2014			2013
U.S. federal statutory rate		35.0	%		35.0	%		35.0	%
Adjustments to reconcile to the effective rate:
	State and local income taxes, net of federal tax benefits	2.8			3.3			4.1
	Changes in valuation allowances (a)	(0.6	)		(3.0	)		15.5
	Taxes on foreign operations at rates different than statutory U.S. federal rates	3.7			1.4			5.9
	Resolution of a prior-year tax matter (b)	(25.6	)		—			—
	Non-deductible debt extinguishment costs	—			—			18.8
	Non-deductible transaction-related costs	0.9			—			3.2
	Other non-deductible expenses	1.8			0.9			2.3
	Other	0.1			(0.1	)		(1.3	)
		18.1	%		37.5	%		83.5	%

__________

^(a)  For the year ended December 31, 2013, includes 13.1% related to our impairment expense.

^(b)  For the year ended December 31, 2015, the Company recognized a $98 million income tax benefit from the resolution of a prior-year income tax matter.

Changes in Gross Unrecognized Tax Benefits

The following is a tabular reconciliation of the gross amount of unrecognized tax benefits for the year:

		2015				2014				2013
Balance at January 1		$	63			$	63			$	54
	Additions for tax positions related to current year	6				5				4
	Additions for tax positions for prior years	3				5				9
	Reductions for tax positions for prior years	(14		)		(8		)		—
	Settlements	(1		)		(2		)		—
	Statute of limitations	(1		)		—				(4		)
Balance at December 31		$	56			$	63			$	63

Unrecognized Tax Benefits

The following table presents unrecognized tax benefits:

	As of December 31,
	2015				2014
Unrecognized tax benefit in non-current income taxes payable (a)	$	37			$	45
Accrued interest payable on potential tax liabilities (b)	28				30

__________

^(a)  Pursuant to the agreements governing the disposition of certain subsidiaries in 2006, the Company is entitled to indemnification for certain pre-disposition tax contingencies. As of December 31, 2015 and 2014, $15 million and $16 million, respectively, of unrecognized tax benefits are related to tax contingencies for which the Company believes it is entitled to indemnification.

^(b)  The Company recognizes potential interest related to unrecognized tax benefits within interest expense related to corporate debt, net on the accompanying Consolidated Statements of Operations. Penalties incurred during the years ended December 31, 2015, 2014 and 2013, were not significant and were recognized as a component of the provision for income taxes.

Vehicle Programs

Income Taxes [Line Items]

Deferred Income Tax Assets and Liabilities

Deferred income tax assets and liabilities related to vehicle programs are comprised of the following:

	As of December 31,
	2015				2014
Deferred income tax assets:
Depreciation and amortization	$	53			$	54
Deferred income tax liabilities:
Depreciation and amortization	2,420				2,321
Deferred income tax liabilities under vehicle programs, net	$	2,367			$	2,267

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Income Taxes [Line Items]

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Summary of income tax contingencies by balance sheet location [table text block]

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Tabular disclosure of the components of income tax expense attributable to continuing operations for each year presented including, but not limited to: current tax expense (benefit), deferred tax expense (benefit), investment tax credits, government grants, the benefits of operating loss carryforwards, tax expense that results from allocating certain tax benefits either directly to contributed capital or to reduce goodwill or other noncurrent intangible assets of an acquired entity, adjustments of a deferred tax liability or asset for enacted changes in tax laws or rates or a change in the tax status of the entity, and adjustments of the beginning-of-the-year balances of a valuation allowance because of a change in circumstances that causes a change in judgment about the realizability of the related deferred tax asset in future years.

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Tabular disclosure of the components of net deferred tax asset or liability recognized in an entity's statement of financial position, including the following: the total of all deferred tax liabilities, the total of all deferred tax assets, the total valuation allowance recognized for deferred tax assets.

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Tabular disclosure of the reconciliation using percentage or dollar amounts of the reported amount of income tax expense attributable to continuing operations for the year to the amount of income tax expense that would result from applying domestic federal statutory tax rates to pretax income from continuing operations.

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Tabular disclosure of income before income tax between domestic and foreign jurisdictions.

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Tabular disclosure of tax positions taken in the tax returns filed or to be filed for which it is more likely than not that the tax position will not be sustained upon examination by taxing authorities (i.e., uncertain tax positions) and other types of income tax contingencies, including: (1) the policy on classification of interest and penalties; (2) a tabular reconciliation of the total amounts of unrecognized tax benefits at the beginning and end of the period; the total amount(s) of: (3) unrecognized tax benefits that, if recognized, would affect the effective tax rate, and (4) interest and penalties recognized in each of the income statement and balance sheet; (5) for positions for which it is reasonably possible that the total amounts unrecognized will significantly change within 12 months of the reporting date the: (i) nature of the uncertainty, (ii) nature of the event that could occur that would cause the change, and (iii) an estimate of the range of the reasonably possible change or a statement that an estimate of the range cannot be made; and (6) a description of tax years that remain subject to examination by major tax jurisdictions.

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