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Income Taxes | 12 Months Ended
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Dec. 31, 2023
Income Tax Disclosure [Abstract] |
Income Taxes | Income Taxes The provision for income taxes consists of the following:
|  | Year Ended December 31,
|  | 2023 |  | 2022 |  | 2021
Current |  |  |  |  |
| Federal | $ | — |  |  | $ | — |  |  | $ | — |
| State | 45 |  |  | 137 |  |  | 35 |
| Foreign | 43 |  |  | 61 |  |  | 12 |
| Current income tax provision | 88 |  |  | 198 |  |  | 47 |
Deferred |  |  |  |  |
| Federal | 77 |  |  | 622 |  |  | 309 |
| State | 47 |  |  | (22) |  |  | 78 |
| Foreign | 67 |  |  | 82 |  |  | (9) |
| Deferred income tax provision | 191 |  |  | 682 |  |  | 378 |
Provision for income taxes | $ | 279 |  |  | $ | 880 |  |  | $ | 425 |
Income before income taxes is comprised of the following:
| Year Ended December 31,
| 2023 |  | 2022 |  | 2021
United States (U.S.) | $ | 1,418 |  |  | $ | 3,114 |  |  | $ | 1,529 |
Foreign | 496 |  |  | 522 |  |  | 179 |
Income before income taxes | $ | 1,914 |  |  | $ | 3,636 |  |  | $ | 1,708 |
Deferred income tax assets, net is comprised of the following:
|  | As of December 31,
|  | 2023 |  | 2022
Deferred income tax assets: |  |  |
| Net tax loss carryforwards | $ | 1,373 |  |  | $ | 1,109 |
| Long-term operating lease liabilities | 703 |  |  | 666 |
| Accrued liabilities and deferred revenue | 169 |  |  | 231 |
| Tax credits | 323 |  |  | 38 |
| Depreciation and amortization | 22 |  |  | 25 |
| Provision for doubtful accounts | 18 |  |  | 19 |
| Other | 213 |  |  | 167 |
| Valuation allowance (a) | (103) |  |  | (101) |
Deferred income tax assets | 2,718 |  |  | 2,154 |
Deferred income tax liabilities: |  |  |
| Operating lease right-of-use assets | 693 |  |  | 657 |
| Depreciation and amortization | 117 |  |  | 90 |
| Prepaid expenses | 33 |  |  | 24 |
| Other | 7 |  |  | 4 |
Deferred income tax liabilities | 850 |  |  | 775 |
Deferred income tax assets, net | $ | 1,868 |  |  | $ | 1,379 |
__________ (a) T he valuation allowance at December 31, 2023 relates to tax loss carryforwards and certain deferred tax assets of $100 million and $3 million, respectively. The valuation allowance at December 31, 2022 relates to tax loss carryforwards and certain deferred tax assets of $97 million and $4 million, respectively. The valuation allowances will be reduced when and if we determine it is more likely than not that the related deferred income tax assets will be realized. Deferred income tax assets and liabilities related to vehicle programs are comprised of the following:
| As of December 31,
| 2023 |  | 2022
Deferred income tax assets: |  |  |
Depreciation and amortization | $ | 80 |  |  | $ | 63 |
Other | 28 |  |  | 22 |
Deferred income tax assets | 108 |  |  | 85 |
Deferred income tax liabilities: |  |  |
Depreciation and amortization | 3,497 |  |  | 2,815 |
Other | 29 |  |  | 24 |
Deferred income tax liabilities | 3,526 |  |  | 2,839 |
Deferred income tax liabilities under vehicle programs, net | $ | 3,418 |  |  | $ | 2,754 |
At December 31, 2023, we had U.S. federal net operating loss carryforwards of approximately $4.9 billion. The majority of the net operating loss carryforwards have an indefinite utilization period pursuant to the Tax Act and a significant remaining portion expires by 2031. Such net operating loss carryforwards are primarily related to accelerated depreciation of our U.S. vehicles. Currently, we do not record valuation allowances on the majority of our U.S. federal tax loss carryforwards as there are adequate deferred tax liabilities that could be realized within the carryforward period. At December 31, 2023, we had foreign net operating loss carryforwards of approximately $1.0 billion, the majority of which has an indefinite utilization period. At December 31, 2023, we had undistributed earnings of certain foreign subsidiaries of approximately $1.6 billion that we have indefinitely reinvested, and on which we have not recognized deferred taxes. Estimating the amount of potential tax is not practicable because of the complexity and variety of assumptions necessary to compute the tax. The reconciliation between the U.S. federal income tax statutory rate and our effective income tax rate is as follows:
|  | Year Ended December 31,
|  | 2023 |  | 2022 |  | 2021
U.S. federal statutory rate | 21.0 | % |  | 21.0 | % |  | 21.0 | %
Adjustments to reconcile to the effective rate: |  |  |  |  |
| State and local income taxes, net of federal tax benefits | 4.0 |  |  | 3.9 |  |  | 5.5 |
| Changes in valuation allowances | — |  |  | (1.3) |  |  | (0.6) |
| Taxes on foreign operations at rates different than U.S. federal statutory rates | 2.8 |  |  | 1.2 |  |  | (2.0) |
| Tax credits (a) | (11.7) |  |  | (0.4) |  |  | — |
| Stock-based compensation | (1.1) |  |  | (0.5) |  |  | (0.3) |
| Other non-deductible (non-taxable) items | 0.7 |  |  | 0.4 |  |  | 0.6 |
| Other (a) | (1.1) |  |  | (0.1) |  |  | 0.7 |
|  | 14.6 | % |  | 24.2 | % |  | 24.9 | %
_______ (a)For the year ended December 31, 2022, we reclassified (0.4%) of certain tax credits to conform to the current year presentation. This reclassification had no impact to our reported effective income tax rate. The following is a tabular reconciliation of the gross amount of unrecognized tax benefits for the year:
|  | 2023 |  | 2022 |  | 2021
Balance, January 1 | $ | 53 |  |  | $ | 58 |  |  | $ | 57 |
| Additions for tax positions related to current year | 5 |  |  | 4 |  |  | 4 |
| Additions for tax positions for prior years | 5 |  |  | 3 |  |  | 3 |
| Reductions for tax positions for prior years | — |  |  | (5) |  |  | (3) |
| Settlements | — |  |  | (5) |  |  | — |
| Statute of limitations | (2) |  |  | — |  |  | — |
| Foreign currency translation | 2 |  |  | (2) |  |  | (3) |
Balance, December 31 | $ | 63 |  |  | $ | 53 |  |  | $ | 58 |
We do not anticipate that total unrecognized tax benefits will change significantly in 2024. We are subject to taxation in the United States and various foreign jurisdictions. As of December 31, 2023, the 2007 through 2022 tax years generally remain subject to examination by the federal tax authorities. The 2012 through 2022 tax years generally remain subject to examination by various state tax authorities. In significant foreign jurisdictions, the 2012 through 2022 tax years generally remain subject to examination by their respective tax authorities. Substantially all of the gross amount of the unrecognized tax benefits at December 31, 2023, 2022 and 2021, if recognized, would affect our provision for income taxes. As of December 31, 2023, our unrecognized tax benefits were offset by tax loss carryforwards and other deferred tax assets in the amount of $28 million. The following table presents unrecognized tax benefits:
| As of December 31,
| 2023 |  | 2022
Unrecognized tax benefits in current income taxes payable (a) | $ | 17 |  |  | $ | — |
Unrecognized tax benefits in non-current income taxes payable (a) | 21 |  |  | 33 |
Accrued interest payable on potential tax liabilities (b) | 44 |  |  | 31 |
__________ (a)Pursuant to the agreements governing the disposition of certain subsidiaries in 2006, we are entitled to indemnification for certain predisposition tax contingencies. As of December 31, 2023, $17 million of unrecognized tax benefits in current income taxes payable are related to tax contingencies which we believe we are entitled to indemnification. As of December 31, 2022, $13 million unrecognized tax benefits in non-current income taxes payable are related to tax contingencies for which we believe we are entitled to indemnification. (b)We recognize 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, 2023, 2022 and 2021, were not significant and were recognized as a component of the provision for income taxes.

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