INCOME TAXES

The components of pretax income for domestic and foreign operations consisted of the following:



	Year Ended December 31,
	2015		2014		2013
Domestic	$	290	$	230	$	192
Foreign	8		4		9
Pretax income	$	298	$	234	$	201

The components of income tax expense (benefit) consisted of the following:



	Year Ended December 31,
	2015		2014		2013
Current:
Federal	$	8	$	5	$	4
State	3		1		—
Foreign	3		4		3
Total current	14		10		7
Deferred:
Federal	91		76		(241		)
State	4		1		(8		)
Foreign	1		—		—
Total deferred	96		77		(249		)
Income tax expense (benefit)	$	110	$	87	$	(242	)

A reconciliation of the Company’s effective income tax rate at the U.S. federal statutory rate of 35% to the actual expense (benefit) was as follows:



	Year Ended December 31,
	2015		2014		2013
Federal statutory rate	35	%	35	%	35	%
State and local income taxes, net of federal tax benefits	2		5		2
Permanent differences	1		2		(1	)
Net change in valuation allowance	1		(3	)	(157	)
Other	(2	)	(2	)	1
	37	%	37	%	(120	%)

The Company’s combined federal, state and foreign effective income tax rate for 2013 is not meaningful since our net definite lived deferred tax assets were fully offset by a valuation allowance until 2013 when we substantially reversed the valuation allowance on our domestic deferred tax assets.

Deferred income taxes result from temporary differences between the amount of assets and liabilities recognized for financial reporting and tax purposes. The components of the deferred income tax assets and liabilities, as of December 31, are as follows:



	2015			2014
Deferred income tax assets:
Net operating loss carryforwards	$	654		$	810
Tax credit carryforwards	28			17
Accrued liabilities	123			103
Minimum pension obligation	23			24
Provision for doubtful accounts	18			22
Liability for unrecognized tax benefits	6			8
Interest rate swaps	11			6
Other	1			—
Total deferred tax assets	864			990
Less: valuation allowance	(11		)	(10		)
Total deferred income tax assets after valuation allowance	853			980
Deferred income tax liabilities:
Depreciation and amortization	1,105			1,122
Change in tax return accounting methods	9			18
Prepaid expenses	2			2
Undistributed foreign earnings	2			6
Basis difference in investment in joint ventures	1			2
Total deferred tax liabilities	1,119			1,150
Net deferred income tax liabilities	$	(266	)	$	(170	)

Deferred tax assets and deferred tax liabilities are netted by tax jurisdiction. The Net deferred income tax liability of $266 million as of December 31, 2015 is included in the accompanying Consolidated Balance Sheets with $267 million in deferred income taxes (non-current liabilities) and $1 million in other non-current assets. The Net deferred income tax liability of $170 million as of December 31, 2014 is included in the accompanying Consolidated Balance Sheets with $171 million in deferred income taxes (non-current liabilities) and $1 million in other non-current assets.

As of December 31, 2015, the Company had gross federal and state net operating loss carryforwards of $1,650 million which is net of losses limited due to the October 2012 ownership change, losses related to excess tax benefits of share-based payments and unrecognized tax benefits. The federal net operating loss carryforwards expire between 2020 and 2033 and the state net operating loss carryforwards expire between 2016 and 2033.

The Company accounts for its deferred tax assets and liabilities related to excess tax benefits of share-based payments, based on the with-and-without method. Since October 2012, the Company generated $11 million of excess tax deductions related to share-based compensation which are not reflected in our NOL deferred tax assets. Equity will be increased by $4 million if and when such deferred tax assets are ultimately realized.

At December 31, 2013, the Company evaluated all available positive and negative evidence and determined that substantially all of the valuation allowance totaling $341 million associated with all U.S. federal and certain state deferred tax assets should be reversed because the Company believed that it had become more likely than not that the value of those deferred tax assets would be realized. In the Company’s evaluation of the need for and amount of a valuation allowance on its deferred tax assets at December 31, 2013, the Company placed the most weight on all objectively verifiable direct evidence, including its recent and historical operating results and the significant improvement in its debt leverage position.

Accounting for Uncertainty in Income Taxes

The Company utilizes the FASB guidance for accounting for uncertainty in income taxes, which prescribes a recognition threshold and a measurement attribute for the financial statement recognition and measurement of tax positions taken or expected to be taken in a tax return. The Company reflects changes in its liability for unrecognized tax benefits as income tax expense in the Consolidated Statements of Operations. As of December 31, 2015, the Company’s gross liability for unrecognized tax benefits was $78 million, of which $34 million would affect the Company’s effective tax rate, if recognized.

The Company files U.S., state and foreign income tax returns in jurisdictions with varying statutes of limitations. Tax returns for the 2006 through 2015 tax years remain subject to examination by federal and certain state tax authorities. In significant foreign jurisdictions, tax returns for the 2008 through 2015 tax years generally remain subject to examination by their respective tax authorities. The Company believes that it is reasonably possible that the total amount of its unrecognized tax benefits could decrease by $3 million in certain taxing jurisdictions where the statute of limitations is set to expire within the next 12 months.

The Company recognizes accrued interest and penalties related to unrecognized tax benefits in interest expense and operating expenses, respectively. The Company recorded a reduction of interest expense of $1 million for the year ended December 31, 2015, no change to interest expense for the year ended December 31, 2014 and a reduction of interest expense of $2 million for the year ended December 31, 2013.

The rollforward of unrecognized tax benefits are summarized in the table below:



Unrecognized tax benefits—January 1, 2013	$	111
Gross increases—tax positions in prior periods	7
Gross increases—tax positions in current period	3
Settlements	(3		)
Reduction due to lapse of statute of limitations	(5		)
Unrecognized tax benefits—December 31, 2013	113
Gross increases—tax positions in prior periods	1
Gross decreases—tax positions in prior periods	(8		)
Gross increases—tax positions in current period	3
Settlements	(1		)
Reduction due to lapse of statute of limitations	(2		)
Unrecognized tax benefits—December 31, 2014	106
Gross decreases—tax positions in prior periods	(4		)
Gross increases—tax positions in current period	1
Settlements	(23		)
Reduction due to lapse of statute of limitations	(2		)
Unrecognized tax benefits—December 31, 2015	$	78

The Company is subject to income taxes in the United States and several foreign jurisdictions. Significant judgment is required in determining the worldwide provision for income taxes and recording related assets and liabilities. In the ordinary course of business, there are many transactions and calculations where the ultimate tax determination is uncertain. The Company is regularly under audit by tax authorities whereby the outcome of the audits is uncertain. The Company believes there is appropriate support for positions taken on its tax returns. The liabilities that have been recorded represent the best estimates of the probable loss on certain positions and are adequate for all open years based on an assessment of many factors including past experience and interpretations of tax law applied to the facts of each matter. However, the outcomes of tax audits are inherently uncertain.

Tax Sharing Agreement

Under the Tax Sharing Agreement with Cendant, Wyndham Worldwide and Travelport, the Company is generally responsible for 62.5% of payments made to settle claims with respect to tax periods ending on or prior to December 31, 2006 that relate to income taxes imposed on Cendant and certain of its subsidiaries, the operations (or former operations) of which were determined by Cendant not to relate specifically to the respective businesses of Realogy, Wyndham Worldwide, Avis Budget or Travelport. With respect to any remaining residual legacy Cendant tax liabilities, the Company and its former parent believe there is appropriate support for the positions taken on Cendant’s tax returns. However, tax audits and any related litigation, including disputes or litigation on the allocation of tax liabilities between parties under the Tax Sharing Agreement, could result in outcomes for the Company that are different from those reflected in the Company’s historical financial statements.