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INCOME TAXES
 12 Months Ended
Dec. 31, 2021
Income Tax Disclosure [Abstract]  
INCOME TAXES INCOME TAXES
Provision for Income Taxes
We are subject to tax in U.S. federal and various state and local jurisdictions, as well as Canada. We are open to federal and significant state income tax examinations for tax year 2016 and subsequent years. The provision for income taxes consists of the following:
Year Ended December 31,
(in millions)202120202019
Current:
Federal
$86 $96 $53 
State
28 30 12 
   Foreign1 1 — 
 Total Current115 127 65 
Deferred:
Federal
(7)(33)(2)
State
(3)(9)(5)
Foreign(2)— — 
Total Deferred(12)(42)(7)
Total$103 $85 $58 
The U.S. federal statutory income tax rate reconciled to our effective tax rate is as follows:
Year Ended December 31,
202120202019
(in millions, except percent)Pre-Tax IncomeTax Expense/(Benefit)Percent of Pre-Tax Income (Loss)Pre-Tax IncomeTax Expense/(Benefit)Percent of Pre-Tax Income (Loss)Pre-Tax IncomeTax Expense/(Benefit)Percent of Pre-Tax Income (Loss)
$441 $357 $270 
U.S. federal statutory tax rate$93 21 %$75 21 %$57 21 %
State income taxes, net of federal benefit32 7 25 7 20 7 
Tax rate change(1)— — — — — 
Nondeductible meals, entertainment and penalties2 — — — 1 — 
Stock based compensation(2)— (2)— (1)— 
Uncertain tax positions(1)— 1 — — — 
Tax credits(7)(2)(6)(2)(7)(3)
State and tax return to provision adjustments(10)(2)(7)(2)(8)(3)
Other(3)(1)(1)— (4)(1)
Total$103 23 %$85 24 %$58 21 %
Our effective income tax rate decreased by 1% to 23% in 2021 from 24% in 2020. The decrease was primarily attributable to benefits associated with a favorable adjustment of our previously disputed receivable from the IRS.
Deferred Income Taxes
Significant components of our deferred tax assets and liabilities are as follows:
Year Ended December 31,
(in millions)20212020
Deferred tax assets:
Net operating losses (federal and state)$3 $3 
Accrued expenses20 14 
Accrued workers' compensation costs9 9 
Recovery credit13 26 
Operating lease liabilities13 15 
Stock based compensation3 3 
Tax benefits relating to uncertain positions1 1 
Tax credits (federal and state)6 8 
Total68 79 
Valuation allowance(5)(5)
Total deferred tax assets63 74 
Deferred tax liabilities:
Depreciation and amortization(37)(37)
Deferred service revenues— (20)
Prepaid commission expenses(24)(22)
Operating lease right-of-use assets(10)(13)
Other(1)(2)
Total deferred tax liabilities(72)(94)
Net deferred tax liabilities$(9)$(20)

As of December 31, 2021, we have an acquired federal net operating loss of $2 million which can be carried forward indefinitely. As of December 31, 2021 and 2020, we have various state net operating loss carryforwards of $45 million and $39 million, respectively, most of which, if unused, will expire in years 2022 through 2040. As of December 31, 2021 and 2020, we have state tax credit carryforwards (net of federal benefit) of $6 million that will begin expiring in 2026.
The provision for income taxes for the year ended December 31, 2021 included $7 million of excess tax benefits resulting from equity incentive plan activities.
We previously paid Notices of Proposed Assessments disallowing employment tax credits totaling $11 million, plus interest of $4 million in connection with the IRS examination of Gevity HR, Inc. and its subsidiaries, which was acquired by TriNet in June 2009. TriNet filed suit in June 2016 to recover the disallowed credits, and the issue is being resolved through the litigation process. TriNet and the U.S. filed cross motions for summary judgment in federal district court. On September 17, 2018, the district court granted our motion for summary judgment and denied the U.S.'s motion. On January 18, 2019, the district court entered judgment in favor of TriNet in the amount of $15 million, plus interest. The U.S. filed a notice of appeal of the federal district court's decision on March 18, 2019. The U.S. filed its opening brief in the court of appeals on June 10, 2019 and we filed our answering brief on July 24, 2019 to which the government filed its reply brief on September 6, 2019. Oral arguments occurred on March 11, 2020. On November 5, 2020, the court of appeals affirmed the district court’s judgement in favor of TriNet. The April 5, 2021 deadline for the IRS to petition the Supreme Court for review passed without a petition. TriNet received payment of the full amount of the judgment in February 2022.
Valuation Allowance
We have recorded a valuation allowance to reflect the estimated amount of deferred tax assets that may not be realized, related to state tax credits and state net operating loss carryforwards. A reconciliation of the beginning and ending amount of the valuation allowance is presented in the table below:
Year Ended December 31,
(in millions)202120202019
Valuation allowance at January 1$5 $5 $7 
(Credited) Charged to net income— — (2)
Valuation allowance at December 315 5 5 
Uncertain Tax Positions
A reconciliation of the beginning and ending amount of unrecognized tax benefits (excluding interest and penalties) related to uncertain income tax provisions, which would affect the effective tax rate if recognized, is presented in the table below:
Year Ended December 31,
(in millions)202120202019
Unrecognized tax benefits at January 1$8 $7 $6 
Additions for tax positions of prior periods
— 1 1 
Additions for tax positions of current period
1 1 1 
Reductions for tax positions of prior period:
Settlements with taxing authorities
— (1)— 
Lapse of applicable statute of limitations
(1)— (1)
Adjustments to tax positions
(1)— — 
Unrecognized tax benefits at December 31$7 $8 $7 
As of December 31, 2021 and 2020, the total amount of gross interest and penalties accrued were immaterial. The unrecognized tax benefit, including accrued interest and penalties, is included in other non-current liabilities on the consolidated balance sheets.
It is reasonably possible the amount of the unrecognized benefit could increase or decrease within the next twelve months, which would have an impact on net income.