11. Income Taxes

The provision for income taxes was calculated based on the following components of earnings (loss) before income taxes:

Continuing operations	2014			2013		2012
U.S.	$	(53	)	$	86	$	32
Non-U.S.		271			249		296

	$	218		$	335	$	328

Discontinued operations	2014			2013			2012
U.S.	$	(19	)	$	(8	)	$	—
Non-U.S.		(4	)		(10	)		(5	)

	$	(23	)	$	(18	)	$	(5	)

The provision (benefit) for income taxes consists of the following:

	2014			2013			2012
Current:
U.S.	$	7		$	7		$	(4	)
Non-U.S.		103			116			117

		110			123			113

Deferred:
U.S.								8
Non-U.S.		(18	)		(3	)		(13	)

		(18	)		(3	)		(5	)

Total:
U.S.		7			7			4
Non-U.S.		85			113			104

Total for continuing operations		92			120			108
Total for discontinued operations								(3	)

	$	92		$	120		$	105

A reconciliation of the provision for income taxes based on the statutory U.S. Federal tax rate of 35% to the provision for income taxes is as follows:

	2014			2013			2012
Tax provision on pretax earnings from continuing operations at statutory U.S. Federal tax rate	$	76		$	117		$	115
Increase (decrease) in provision for income taxes due to:
Differences in income taxes on foreign earnings, losses and remittances		(18	)		(29	)		(5	)
Changes in valuation allowance		37			37			(7	)
Tax audits and settlements		2			1			(1	)
Other items		(5	)		(6	)		6

Provision for income taxes	$	92		$	120		$	108

Deferred income taxes reflect: (1) the net tax effects of temporary differences between the carrying amounts of assets and liabilities for financial reporting purposes and the amounts used for income tax purposes; and (2) carryovers and credits for income tax purposes.

Significant components of the Company's deferred tax assets and liabilities at December 31, 2014 and 2013 are as follows:

	2014			2013
Deferred tax assets:
Accrued postretirement benefits	$	58		$	60
Asbestos-related liabilities		152			157
Foreign tax credit		376			356
Operating and capital loss carryovers		464			489
Other credit carryovers		37			46
Accrued liabilities		85			89
Pension liability		117			47
Other		65			73

Total deferred tax assets		1,354			1,317
Deferred tax liabilities:
Property, plant and equipment		127			126
Exchangeable notes					10
Intangibles		34			27
Other		36			59

Total deferred tax liabilities		197			222
Valuation allowance		(1,036	)		(990	)

Net deferred taxes	$	121		$	105

Deferred taxes are included in the Consolidated Balance Sheets at December 31, 2014 and 2013 as follows:

	2014			2013
Prepaid expenses	$	39		$	64
Other assets		203			237
Deferred taxes		(121	)		(196	)

Net deferred taxes	$	121		$	105

The Company reviews the likelihood that it will realize the benefit of its deferred tax assets and therefore the need for valuation allowances on a quarterly basis, or whenever events indicate that a review is required. In determining the requirement for a valuation allowance, the historical and projected financial results of the legal entity or consolidated group recording the net deferred tax asset is considered, along with other positive and negative evidence.

At December 31, 2014, before valuation allowance, the Company had unused foreign tax credits of $376 million expiring in 2017 through 2024, research tax credit of $12 million expiring from 2019 to 2034, and alternative minimum tax credits of $25 million which do not expire and which will be available to offset future U.S. Federal income tax. Approximately $174 million of the deferred tax assets related to operating and capital loss carryforwards can be carried over indefinitely, with the remaining $290 million expiring between 2015 and 2035.

In certain foreign jurisdictions, the Company's analysis indicates that it has cumulative losses in recent years. This is considered significant negative evidence which is objective and verifiable and, therefore, difficult to overcome. However, the cumulative loss position is not solely determinative and, accordingly, the Company considers all other available positive and negative evidence in its analysis. Based on its analysis, the Company has recorded a valuation allowance for the portion of deferred tax assets where based on the weight of available evidence it is unlikely to realize those deferred tax assets.

In the U.S., the Company has experienced cumulative losses in previous years and has recorded a valuation allowance against its deferred tax assets. As of December 31, 2014 however, the Company's U.S. operations are in a three-year cumulative income position, but this is not solely determinative of the need for a valuation allowance. The Company considered this factor and all other available positive and negative evidence and concluded that it is still more likely than not that the net deferred tax assets in the U.S. will not be realized, and accordingly continued to record a valuation allowance. The evidence considered included the magnitude of the current three-year cumulative income compared to historical losses, expected impact of tax planning strategies, interest rates, and the overall business environment. The Company continues to evaluate its cumulative income position and income trend as well as its future projections of sustained profitability and whether this profitability trend constitutes sufficient positive evidence to support a reversal of the valuation allowance (in full or in part). The amount of the valuation allowance recorded in the U.S. as of December 31, 2014 is $927 million.

At December 31, 2014, the Company's equity in the undistributed earnings of foreign subsidiaries for which income taxes had not been provided approximated $2.9 billion. The Company intends to reinvest these earnings indefinitely in the non-U.S. operations and has not distributed any of these earnings to the U.S. in 2014, 2013 or 2012. It is not practicable to estimate the U.S. and foreign tax which would be payable should these earnings be distributed. Deferred taxes are provided for earnings of non-U.S. jurisdictions when the Company plans to remit those earnings.

The Company has recognized tax benefits as a result of incentives in certain non-U.S. jurisdictions which expire between 2015 and 2016.

The Company records a liability for unrecognized tax benefits related to uncertain tax positions. The Company accrues interest and penalties associated with unrecognized tax benefits as a component of its income tax expense. The following is a reconciliation of the Company's total gross unrecognized tax benefits for the years ended December 31, 2014, 2013 and 2012:

	2014			2013			2012
Balance at January 1	$	100		$	97		$	125
Additions and reductions for tax positions of prior years		(13	)		(3	)		8
Additions based on tax positions related to the current year		10			9			7
Reductions due to the lapse of the applicable statute of limitations		(8	)		(2	)		(21	)
Reductions due to settlements		(1	)					(26	)
Foreign currency translation		(11	)		(1	)		4

Balance at December 31	$	77		$	100		$	97


Unrecognized tax benefits, which if recognized, would impact the Company's effective income tax rate	$	70		$	92		$	89


Accrued interest and penalties at December 31	$	29		$	35		$	33


Interest and penalties included in tax expense for the years ended December 31	$	(2	)	$	1		$	(6	)

Based upon the outcome of tax examinations, judicial proceedings, or expiration of statute of limitations, it is reasonably possible that the ultimate resolution of these unrecognized tax benefits may result in a payment that is materially different from the current estimate of the tax liabilities. The Company believes that it is reasonably possible that the estimated liability could decrease up to $12 million within the next 12 months. This is primarily the result of audit settlements or statute expirations in several taxing jurisdictions.

The Company is currently under examination in various tax jurisdictions in which it operates, including Argentina, Brazil, Canada, Germany, Indonesia, Italy and Peru. The years under examination range from 2005 through 2012. The Company believes that there are no jurisdictions in which the outcome of unresolved issues or claims is likely to be material to the Company's results of operations, financial position or cash flows. The Company further believes that adequate provisions for all income tax uncertainties have been made. During 2014, the Company concluded income tax audits in several jurisdictions, including Australia, Ecuador, Italy, and Poland.