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Income Taxes
 12 Months Ended
Dec. 31, 2024
Income Tax Disclosure [Abstract]  
Income Taxes Income Taxes
The components of income before income taxes for the periods were as follows (in millions):
Years Ended December 31,
202420232022
Domestic$302 $443 $426 
Foreign(11)4 8 
Income before income taxes$291 $447 $434 

The provision for income taxes consists of the following (in millions):
Years Ended December 31,
202420232022
Current:
Federal$8 $— $— 
Foreign4 4 5 
State and local9 7 15 
Total current21 11 20 
Deferred:
Federal63 86 82 
Foreign(6)(1)— 
State and local2 4 2 
Total deferred59 89 84 
Total income tax provision$80 $100 $104 

The principal items of the U.S. and foreign net deferred tax assets (liabilities) are as follows (in millions):
December 31, 2024December 31, 2023
Deferred tax assets:
Employee benefit plans$4 $6 
Tax credit carryforwards5 3 
Right-of-use assets230 185 
Deferred interest80 58 
Accrued expenses59 55 
Net operating loss carryforwards42 108 
Total deferred tax assets420 415 
Less: valuation allowance(5)(2)
Total net deferred tax assets415 413 
Deferred tax liabilities:
Lease liabilities(218)(179)
Prepaid expenses(4)(3)
Depreciation on tangible assets(913)(899)
Intangible assets(80)(75)
Total deferred tax liabilities(1,215)(1,156)
Net deferred tax liability$(800)$(743)
Management also records deferred tax assets for unutilized net operating loss carryforwards in various tax jurisdictions. As of December 31, 2024, a deferred tax asset of $26 million was recorded for unutilized federal net operating loss carryforwards ("NOL carryforwards"). The total federal NOL carryforwards are $136 million and have an indefinite carryforward period. State NOL carryforwards have generated a deferred tax asset of $16 million and expire over various years beginning in 2025.

As of December 31, 2024, deferred tax assets of $5 million were recorded for federal and various state tax credit carryforwards and expire in various years beginning in 2036.

In determining the valuation allowance, an assessment of positive and negative evidence was performed regarding realization of the net deferred tax assets in accordance with Topic 740. This assessment included the evaluation of scheduled reversals of deferred tax liabilities, the availability of carryforwards and estimates of projected future taxable income. Based on the assessment, as of December 31, 2024, total valuation allowances of $5 million were recorded against deferred tax assets. Although realization is not assured, the Company has concluded that it is more likely than not the remaining deferred tax assets of $415 million will be realized and as such no valuation allowance has been provided on these assets.

The income tax in the accompanying consolidated statements of operations differs from the income tax calculated by applying the statutory federal income tax rate to income before income taxes due to the following (in millions):
Years Ended December 31,
202420232022
Income tax provision at statutory rate$61 $93 $91 
Increases (decreases) resulting from:
Foreign taxes— 5 — 
State and local income taxes, net of federal income tax9 10 14 
Federal and foreign permanent items2 (1)(1)
Change in valuation allowance— (2)— 
Goodwill impairment(a)
14 — — 
Tax credits(6)(6)(1)
All other items, net— 1 1 
Income tax provision$80 $100 $104 
(a) Relates to non-deductible goodwill impairment on Cinelease assets held for sale.

As a result of the Tax Cuts and Jobs Act of 2017, previously undistributed earnings from foreign subsidiaries are deemed to have been repatriated as of December 31, 2017 for federal income tax purposes. Beginning in 2018, companies are generally able to repatriate earnings from foreign subsidiaries with no U.S. federal income tax impact. As of December 31, 2024, the Company continues to assert that earnings from foreign operations are not permanently invested. The Company, as a matter of policy, looks to repatriate foreign earnings in a tax efficient manner. Many foreign jurisdictions impose taxes on distributions to other jurisdictions. Due to the variations and complexities of these laws, the Company believes it would be impractical to calculate and accrue these taxes beyond the normal earnings and profits standard for U.S. tax purposes.

As of December 31, 2024, the Company is maintaining the assertion that future earnings associated with the potential stock sale or liquidation of foreign subsidiaries are permanently reinvested. Accordingly, the Company has not recorded any deferred tax liabilities associated with these book-to-tax differences. The Company has analyzed the potential tax liability associated with these differences to be approximately $67 million.

The total cumulative amount of unrecognized tax benefits is $15 million and $12 million as of December 31, 2024 and 2023, respectively.

The Company files one or more income tax returns in the U.S. and non-U.S. jurisdictions. In the normal course of business, the Company is subject to examination by taxing authorities and open tax years span from 2014 to 2023. The Company is currently under audit for the 2014 through 2016 income tax years. Several U.S. state and non-U.S. jurisdictions are under audit. The IRS completed its audit of the Company's 2016 consolidated income tax return, in which Herc was included, and had no changes to the previously filed tax return. The Company is under audit for 2024 as part of the IRS Compliance Assurance Program. The Company does not expect any material assessments resulting from these audits.
The Organization for Economic Co-operation and Development (OECD) has a framework to implement a global minimum corporate tax of 15% for companies with global revenues and profits above certain thresholds (referred to as "Pillar 2"), with certain aspects of Pillar 2 effective January 1, 2024 and other aspects effective January 1, 2025. While it is uncertain whether the U.S. will enact legislation to adopt Pillar 2, certain countries have adopted legislation, and other countries are in the process of introducing legislation to implement Pillar 2. We have evaluated the impact of Pillar 2 on our effective tax rate, our consolidated results of operation, financial position, and cash flows and have determined there is no impact to the Company in 2024.