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Income Taxes (Tables)

12 Months Ended

Dec. 31, 2018

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,
		2018				2017				2016
Current
	Federal	$	(7	)		$	—			$	(1	)
	State	36				5				3
	Foreign	59				37				63
	Current income tax provision	88				42				65
Deferred
	Federal	63				(205		)		51
	State	(39		)		(5		)		5
	Foreign	(10		)		18				(5		)
	Deferred income tax provision	14				(192		)		51
Provision for (benefit from) income taxes		$	102			$	(150	)		$	116

Pretax Income (Loss) for Domestic and Foreign Operations

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

	Year Ended December 31,
	2018				2017				2016
United States	$	114			$	17			$	127
Foreign	153				194				152
Pretax income	$	267			$	211			$	279

Deferred Income Tax Assets and Liabilities

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

		As of December 31,
		2018				2017
Deferred income tax assets:
	Net tax loss carryforwards	$	1,390			$	1,104
	Accrued liabilities and deferred revenue	230				216
	Tax credits	17				24
	Depreciation and amortization	16				4
	Provision for doubtful accounts	6				8
	Other	38				50
	Valuation allowance (a)	(311		)		(331		)
Deferred income tax assets		1,386				1,075
Deferred income tax liabilities:
	Depreciation and amortization	60				121
	Prepaid expenses	20				20
	Other	5				3
Deferred income tax liabilities		85				144
Deferred income tax assets, net		$	1,301			$	931

__________

^(a)  The valuation allowance of $311 million at December 31, 2018 relates to tax loss carryforwards and certain deferred tax assets of $283 million and $28 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 $331 million at December 31, 2017 relates to tax loss carryforwards and certain deferred tax assets of $302 million and $29 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 re

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,
		2018			2017			2016
U.S. federal statutory rate		21.0	%		35.0	%		35.0	%
Adjustments to reconcile to the effective rate:
	State and local income taxes, net of federal tax benefits	5.5			3.8			2.0
	Changes in valuation allowances	6.3			(4.7	)		(0.2	)
	Taxes on foreign operations at rates different than statutory U.S. federal rates	(5.2	)		(3.6	)		3.1
	Stock-based compensation	(0.8	)		(3.4	)		—
	Tax Act (benefit) expense	11.2			(100.8	)		—
	Other non-deductible expenses	1.1			2.2			1.7
	Other	(0.9	)		0.4			—
		38.2	%		(71.1	)%		41.6	%

Changes in Gross Unrecognized Tax Benefits

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

		2018				2017				2016
Balance at January 1		$	63			$	59			$	56
	Additions for tax positions related to current year	8				6				3
	Additions for tax positions for prior years	—				9				3
	Reductions for tax positions for prior years	(6		)		(10		)		(3		)
	Settlements	(3		)		—				—
	Statute of limitations	(1		)		(1		)		—
Balance at December 31		$	61			$	63			$	59

Unrecognized Tax Benefits

The following table presents unrecognized tax benefits:

	As of December 31,
	2018				2017
Unrecognized tax benefit in non-current income taxes payable (a)	$	41			$	46
Accrued interest payable on potential tax liabilities (b)	29				26

__________

^(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, 2018 and 2017, $13 million 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, 2018, 2017 and 2016, 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,
	2018				2017
Deferred income tax assets:
Depreciation and amortization	$	44			$	58
Deferred income tax liabilities:
Depreciation and amortization	2,005				1,652
Deferred income tax liabilities under vehicle programs, net	$	1,961			$	1,594

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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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