9. Income Taxes

In connection with the Separation, the Company and NOV entered into a Tax Matters Agreement, dated as of May 29, 2014 (the “Tax Matters Agreement”). The Tax Matters Agreement sets forth the Company and NOV’s rights and obligations related to the allocation of federal, state, local and foreign taxes for periods before and after the Spin-Off, as well as taxes attributable to the Spin-Off, and related matters such as the filing of tax returns and the conduct of IRS and other audits. Pursuant to the Tax Matters Agreement, NOV has prepared and filed the consolidated federal income tax return, and any other tax returns that include both NOV and the Company for all the liability periods ended on or prior to May 30, 2014. The income tax provision (benefit) for periods prior to the Separation has been computed as if NOW were a stand-alone company. NOV will indemnify and hold harmless the Company for any income tax liability for periods before the Separation date. The Company will prepare and file all tax returns that include solely the Company for all taxable periods ending after that date. Settlements of tax payments between NOV and the Company were generally treated as contributions from or distributions to NOV in periods prior to the Separation date.

The domestic and foreign components of income (loss) before income taxes were as follows (in millions):

	Year Ended December 31,
	2015			2014		2013
United States	$	(524	)	$	101	$	161
Foreign		6			77		61
Income (loss) before income taxes	$	(518	)	$	178	$	222

The provision (benefit) for income taxes for 2015, 2014 and 2013 consisted of the following (in millions):

	2015			2014			2013
U.S. Federal:
Current	$	(14	)	$	38		$	48
Deferred		(2	)		3			6
		(16	)		41			54
U.S. State:
Current		(1	)		4			4
Deferred		—			—			—
		(1	)		4			4
Foreign
Current		5			18			20
Deferred		(4	)		(1	)		(3	)
		1			17			17
Income tax provision (benefit)	$	(16	)	$	62		$	75

The reconciliation between the Company’s effective tax rate on income (loss) from continuing operations and the statutory tax rate is as follows (in millions):

	Year Ended December 31,
	2015			2014			2013
Income tax provision (benefit) at federal statutory rate	$	(181	)	$	62		$	78
Foreign tax rate differential		(1	)		(6	)		(5	)
State income tax provision (benefit), net of federal benefit		(8	)		3			3
Nondeductible expenses		3			2			2
Foreign tax credits		(3	)		—			(1	)
Nondeductible goodwill impairment		42			—			—
Change in valuation allowance		129			—			—
Change in contingency reserve and other		3			1			(2	)
Income tax provision (benefit)	$	(16	)	$	62		$	75

Effective tax rate		3.0	%		34.9	%		33.8	%

In 2015, the effective tax rate was impacted by nondeductible goodwill impairments and a valuation allowance recorded against the Company’s deferred tax assets in the United States.

Significant components of the Company’s deferred tax assets and liabilities were as follows (in millions):

	Year Ended December 31,
	2015			2014			2013
Deferred tax assets:
Allowances and operating liabilities	$	9		$	2		$	12
Net operating loss carryforwards		13			1			1
Foreign tax credit carryforwards		3			—			—
Book over tax depreciation		—			—			2
Trade credit		4			4			1
Allowance for doubtful accounts		12			3			2
Inventory reserve		11			9			11
Stock-based compensation		19			12			5
Intangible assets		56			—			—
Other		1			3			2
Total deferred tax assets		128			34			36
Deferred tax liabilities:
Tax over book depreciation		(6	)		(2	)		(2	)
Intangible assets		—			(18	)		(14	)
Total deferred tax liabilities		(6	)		(20	)		(16	)

Net deferred tax assets before valuation allowance		122			14			20
Valuation allowance		(129	)		—			—
Net deferred tax assets (liability)	$	(7	)	$	14		$	20

We record a valuation allowance when it is more-likely-than-not that some portion or all of the deferred tax assets will not be realized. The ultimate realization of the deferred tax assets depends on the ability to generate sufficient taxable income of the appropriate character in the future and in the appropriate taxing jurisdictions. If we were to determine that we would be able to realize our deferred tax assets in the future in excess of their net recorded amount, we would make an adjustment to the valuation allowance, which would reduce the provision for income taxes.

Based upon the significant level of recent U.S. losses, management believes that it is not more-likely-than-not that the Company would be able to realize the benefits of the deferred tax assets and accordingly recognized a valuation allowance for the year ended December 31, 2015. The change during the year in the valuation allowance was $129 million, all of which relates to 2015.

Effective December 31, 2015, we early adopted, on a prospective basis, FASB ASU No. 2015-17, “Balance Sheet Classification of Deferred Taxes.” This ASU requires all deferred tax assets and liabilities to be reported as noncurrent. Noncurrent assets and liabilities include deferred taxes of $4 million and $11 million, respectively, at December 31, 2015. Current assets, noncurrent assets, current liabilities and noncurrent liabilities included deferred taxes of $22 million, $2 million, $0 million and $10 million, respectively, at December 31, 2014.

A reconciliation of the beginning and ending amount of unrecognized tax benefits is as follows (in millions):

	2015		2014		2013
Unrecognized tax benefit at January 1	$	—	$	—	$	2
Gross increases - tax positions in prior period		—		—		—
Gross decreases - tax positions in prior period		—		—		—
Gross increases - tax positions in current period		1		—		—
Settlement		—		—		—
Lapse of statute of limitations		—		—		(2	)
Unrecognized tax benefit at December 31	$	1	$	—	$	—

The balance of unrecognized tax benefits at December 31, 2015 and 2014 was $1 million and $0 million, respectively. Included in the change in the balance of unrecognized tax benefits for the period ended December 31, 2015 was an increase of $1 million of unrecognized tax benefits associated with uncertain income tax positions. These unrecognized tax benefits are included as a reduction to deferred tax assets in the Consolidated Balance Sheet at December 31, 2015. If the $1 million of unrecognized tax benefits accrued at December 31, 2015 are ultimately realized, $1 million would be recorded as a reduction of income tax expense.

The Company does not anticipate that the total unrecognized tax benefits will significantly change due to the settlement of audits or the expiration of statutes of limitation within 12 months of this reporting date.

To the extent penalties and interest would be assessed on any underpayment of income tax, such accrued amounts are classified as a component of income tax expense in the financial statements consistent with the Company’s policy. During the year ended December 31, 2015, the Company did not record any income tax expense for interest and penalties related to uncertain tax positions. At December 31, 2015, the Company has not accrued any interest and penalties relating to unrecognized tax benefits.

The Company is subject to taxation in the United States, various states and foreign jurisdictions. The Company has significant operations in the United States and Canada and to a lesser extent in various other international jurisdictions. Tax years that remain subject to examination by major tax jurisdictions vary by legal entity, but are generally open in the U.S. for the tax years ending after 2011 and outside the U.S. for the tax years ending after 2009. The Company is indemnified for any income tax expense exposures related to periods prior to the Separation.

In the United States, the Company has $30 million and $0 million of net operating loss carryforwards as of December 31, 2015 and December 31, 2014, which will expire in 2035. The potential benefit of $11 million has been reduced by an $11 million valuation allowance. Future income tax payments will be reduced in the event the Company ultimately realizes the benefit of these net operating losses. In addition to future income tax expense, future income tax payments will also be reduced in the event the Company ultimately realizes the benefit of these net operating losses.

Outside the United States, the Company has $7 million and $4 million of net operating loss carryforwards as of December 31, 2015 and December 31, 2014, of which $5 million have no expiration and $2 million will expire in future years through 2025.

Also in the United States, the Company has $3 million and $0 million of excess foreign tax credits as of December 31, 2015 and December 31, 2014. The potential benefit of $3 million has been reduced by a $3 million valuation allowance. In addition to future income tax expense, future income tax payments will also be reduced in the event the Company ultimately realizes the benefit of these foreign tax credits.

In general, it is the practice and intention of the Company to reinvest the earnings of its non-U.S. subsidiaries in those operations. As of December 31, 2015, the amount of undistributed earnings of foreign subsidiaries was approximately $180 million. The Company has not, nor does it anticipate the need to, repatriate funds to the United States to satisfy domestic liquidity needs arising in the ordinary course of business, including liquidity needs associated with domestic debt service requirements. These earnings are considered to be permanently reinvested and no provision for U.S. federal and state income taxes has been made. Distribution of these earnings in the form of dividends or otherwise could result in U.S. federal taxes (subject to an adjustment for foreign tax credits) and withholding taxes payable in various foreign countries. Determination of the amount of unrecognized deferred U.S. income tax liability is not practical; however, unrecognized foreign tax credit carryforwards would be available to reduce some portion of the U.S. liability.

Because of the number of tax jurisdictions in which the Company operates, its effective tax rate can fluctuate as operations and the local country tax rates fluctuate. The Company is also subject to audits by federal, state and foreign jurisdictions which may result in proposed assessments. The Company’s future tax provision will reflect any favorable or unfavorable adjustments to its estimated tax liabilities when resolved. The Company is unable to predict the outcome of these matters. However, the Company believes that none of these matters will have a material adverse effect on the results of operations or financial position of the Company.