In accordance with the adoption of ASU 2023-09, a reconciliation of income taxes at the U.S. statutory rate to United States and Foreign Tax Expense for the year ended December 31, 2025 is as follows: | | | | | | | | | | | | | (In millions) | 2025 | | % | U.S. federal income tax expense (benefit) at the statutory rate of 21% | $ | (28) | | | 21.0 | % | State income taxes, net of U.S. federal benefit(1) | 183 | | | (137.4) | % | | Foreign tax effects | | | | | Luxembourg | | | | | Changes in valuation allowances | (53) | | | 39.6 | % | | Rate differential | 11 | | | (8.0) | % | | Other | (1) | | | 1.1 | % | | Other foreign jurisdictions | 57 | | | (42.7) | % | | Effect of cross-border tax laws | (13) | | | 9.8 | % | | Tax credits | | | | | Research and development credits | (6) | | | 4.5 | % | | Changes in valuation allowances | 1,267 | | | (949.1) | % | | Nontaxable or nondeductible items | | | | | Goodwill impairment | 140 | | | (104.8) | % | | Changes in unrecognized tax benefits | 9 | | | (6.7) | % | | Other Adjustments | 1 | | | (1.0) | % | | United States and Foreign Tax Expense | $ | 1,567 | | | (1,173.7) | % |
| | | | | | (1) State taxes in Pennsylvania, Illinois, Michigan, Kansas, California, Louisiana and Georgia made up the majority (greater than 50 percent) of the tax effect in this category. |
For the years ended December 31, 2024 and 2023, prior to the adoption of ASU 2023-09, a reconciliation of income taxes at the U.S. statutory rate to United States and Foreign Tax Expense for the years then ended is as follows: | | | | | | | | | | | | | (In millions) | 2024 | | 2023 | U.S. federal income tax expense (benefit) at the statutory rate of 21% | $ | 27 | | | $ | (151) | | Net foreign losses with no tax due to valuation allowances | 48 | | | 122 | | | Adjustment for foreign income taxed at different rates and nontaxable foreign items | 44 | | | 14 | | U.S. charges (benefits) related to foreign tax credits, R&D and foreign derived intangible deduction | (30) | | | 4 | | Net establishment (release) of uncertain tax positions | 6 | | | (3) | | Net establishment of foreign valuation allowances and write-off of deferred taxes | 4 | | | — | | | State income taxes, net of U.S. federal benefit | (8) | | | (12) | | Net establishment of U.S. valuation allowances | 4 | | | — | | | Goodwill impairment | — | | | 34 | | | | | | | Other | — | | | 2 | | | United States and Foreign Tax Expense | $ | 95 | | | $ | 10 | |
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