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Income Taxes
 12 Months Ended
Dec. 31, 2020
Income Tax Disclosure [Abstract]  
Income Taxes Income Taxes
Our income tax expense (benefit) consisted of the following for the years ended December 31 (in millions):
202020192018
Deferred:
Federal$(247)$119 $82 
State(82)20 7 
Foreign— — 1 
Deferred income tax (benefit) expense(329)139 90 
Current:
Federal(199)36 (61)
State(9)19 (5)
Foreign(2)5 6 
Current income tax (benefit) expense(210)60 (60)
Total income tax (benefit) expense$(539)$199 $30 
On March 27, 2020, the CARES Act was enacted in response to the COVID-19 pandemic. The CARES Act permits net operating loss (NOL) carryovers and carrybacks to offset 100% of taxable income for taxable years beginning before 2021. In addition, the CARES Act allows NOLs incurred in 2018, 2019, and 2020 to be carried back to each of the five preceding taxable years to generate a refund of previously paid incomes taxes. As a result, the Company’s effective tax rate includes an income tax benefit related to the anticipated refunds from tax losses generated during 2020 that are permitted to be carried back to certain years when the U.S. federal income tax rate was 35%.
The effective tax rate on income before income taxes differed from the federal income tax statutory rate for the years ended December 31 for the following reasons (in millions):
202020192018
Income tax (benefit) expense at statutory rate$(398)$161 $45 
State income tax, net of federal benefit(71)31 8 
Adjustment of net deferred tax liability from enacted tax rate change— — (28)
Nondeductible expenses5 8 5 
Net operating loss carryback(73)— — 
Foreign tax credit re-characterization(13)— — 
Foreign rate differential2 (3)(2)
Valuation allowance10 — — 
Unrecognized tax benefit(3)— — 
Other, net2 2 2 
Total income tax (benefit) expense$(539)$199 $30 
The components of our deferred tax assets and liabilities as of December 31 are as follows (in millions):
20202019
Deferred tax assets:
Deferred revenue/gains$161 $127 
Employee benefits71 47 
Foreign tax credit81 42 
Net operating loss carryforward335 31 
Operating lease liabilities204 212 
Rent expense33 17 
Total deferred tax assets885 476 
Valuation allowance(69)(31)
Deferred tax assets, net816 445 
Deferred tax liabilities:
Accelerated depreciation(1,538)(1,423)
Operating lease assets(197)(236)
Other(3)(37)
Total deferred tax liabilities(1,738)(1,696)
Net deferred tax liability$(922)$(1,251)
We have a U.S. foreign tax credit carryforward of $79 million which expires in 2028.
In evaluating the realizability of the deferred tax assets, we assess whether it is more likely than not that some portion, or all, of the deferred tax assets, will be realized. We consider, among other things, the generation of future taxable income (including reversals of deferred tax liabilities) during the periods in which the related temporary differences will become deductible. At December 31, 2020, we provided a $69 million valuation allowance to reduce the deferred tax assets to an amount that we consider is more likely than not to be realized. Of the total valuation allowance, $59 million relates to foreign NOL carryforward, and $10 million relates to U.S. foreign tax credit carryforward that begins to expire in 2021.
A reconciliation of the beginning and ending amount of unrecognized tax benefits is as follows (in millions):
202020192018
Unrecognized tax benefits at January 1,$36 $33 $31 
Increases for tax positions taken during the period1 6 5 
Decreases for tax positions taken during a prior period(5)(3)(3)
Unrecognized tax benefits December 31,$32 $36 $33 
Interest and penalties accrued on unrecognized tax benefits were not significant. If recognized, $12 million of the unrecognized tax benefits as of December 31, 2020 would impact our effective tax rate. We do not expect any significant change in the amount of the unrecognized tax benefits within the next twelve months. As a result of net operating losses and statute of limitations in our major tax jurisdictions, years 2004 through 2019 remain subject to examination by the relevant tax authorities.