INCOME TAXES

The components of pretax (loss) income for the years ended December 31, 2014, 2013 and 2012 were as follows (in thousands):



	Year Ended December 31,
	2014			2013			2012
United States	$	(20,057	)	$	62,021		$	88,638
International	(28,138		)	(80,930		)	6,304
(Loss) income before provision for income taxes	$	(48,195	)	$	(18,909	)	$	94,942

The provision for income taxes for the years ended December 31, 2014, 2013 and 2012 consisted of the following components (in thousands):



	Year Ended December 31,
	2014			2013			2012
Current taxes:
U.S. federal	$	(3,518	)	$	22,321		$	41,551
State	69			1,693			4,778
International	30,279			64,078			107,295
Total current taxes	26,830			88,092			153,624
Deferred taxes:
U.S. federal	(5,132		)	4,675			(2,977		)
State	(742		)	(5,687		)	(236		)
International	(5,232		)	(17,043		)	(4,438		)
Total deferred taxes	(11,106		)	(18,055		)	(7,651		)
Provision for income taxes	$	15,724		$	70,037		$	145,973

The items accounting for differences between the income tax provision or benefit computed at the federal statutory rate and the provision for income taxes for the years ended December 31, 2014, 2013 and 2012 were as follows:



	Year Ended December 31,
	2014			2013			2012
U.S. federal income tax (benefit) provision at statutory rate	$	(16,868	)	$	(6,618	)	$	33,230
Foreign income and losses taxed at different rates	4,815			14,299			10,565
Unrecognized tax benefits on E-Commerce transaction	—			—			17,404
State income taxes, net of federal benefits and state tax credits	(10,051		)	(5,361		)	3,965
Change in valuation allowances	23,515			24,404			29,249
Effect of foreign and state rate changes on deferred items	178			837			(487		)
Tax effects of intercompany transactions⁽¹⁾	13,098			35,158			31,011
Non-deductible stock-based compensation expense	6,503			9,000			14,641
Federal research and development credits	(4,693		)	(4,650		)	—
Non-deductible or non-taxable items	(773		)	2,968			6,395
Provision for income taxes	$	15,724		$	70,037		$	145,973


(1)	Includes a tax benefit of $24.4 million for the year ended December 31, 2014 resulting from decreases in the Company's liabilities for uncertain tax positions.

The deferred income tax assets and liabilities consisted of the following components as of December 31, 2014 and 2013 (in thousands):



	December 31,
	2014			2013
Deferred tax assets:
Reserves and allowances	$	32,379		$	65,356
Stock-based compensation	6,911			13,462
Net operating loss and tax credit carryforwards	221,674			152,271
Intangible assets, net	11,910			30,039
Investments	1,441			3,730
Unrealized foreign exchange losses	5,011			—
Other	2,610			1,692
Total deferred tax assets	281,936			266,550
Less valuation allowances	(205,486		)	(173,577		)
Deferred tax assets, net of valuation allowance	76,450			92,973
Deferred tax liabilities:
Unrealized foreign exchange gains	—			(3,034		)
Prepaid expenses and other assets	(1,455		)	(1,078		)
Property, equipment and software, net	(25,159		)	(19,239		)
Deferred revenue	(25,013		)	(64,154		)
Total deferred tax liabilities	(51,627		)	(87,505		)
Net deferred tax asset	$	24,823		$	5,468

The Company regularly reviews deferred tax assets to assess whether it is more likely than not that the deferred tax assets will be realized and, if necessary, establishes a valuation allowance for portions of such assets to reduce the carrying value. For purposes of assessing whether it is more likely than not that the Company's deferred tax assets will be realized, the Company considers the following four sources of taxable income for each tax jurisdiction: (a) future reversals of existing taxable temporary differences, (b) projected future earnings, (c) taxable income in carryback years, to the extent that carrybacks are permitted under the tax laws of the applicable jurisdiction, and (d) tax planning strategies, which represent prudent and feasible actions that a company ordinarily might not take, but would take to prevent an operating loss or tax credit carryforward from expiring unused. The Company has incurred significant losses in recent years and had accumulated deficits of $922.0 million and $848.9 million as of December 31, 2014 and 2013, respectively. A cumulative loss in the most recent three-year period is a significant piece of negative evidence that is difficult to overcome when assessing the realizability of deferred tax assets. The Company has only recognized deferred tax assets to the extent that they will be realizable either through future reversals of existing taxable temporary differences, through taxable income in carryback years for the applicable jurisdictions or based on projections of future income for those jurisdictions in a cumulative income position for the most recent three-year period. During the fourth quarter of 2013, earnings in the United States moved to a cumulative income position for the most recent three-year period and the Company released a portion of the valuation allowance against its federal and state deferred tax assets, resulting in a $9.6 million reduction to income tax expense. The Company continues to maintain a valuation allowance in the United States against a portion of its acquired domestic federal net operating losses that are subject to limitations under the tax law and state net operating loss carryforwards and tax credits that are not expected to be realized. As of December 31, 2014 and 2013, the Company recorded a valuation allowance of $205.5 million and $173.6 million, respectively, against its domestic and foreign net deferred tax assets, as it believes it is more likely than not that these benefits will not be realized.

The Company had $121.2 million of federal and $270.5 million of state net operating loss carryforwards as of December 31, 2014 which will begin expiring in 2027 and 2016, respectively. As of December 31, 2014, the Company had $714.9 million of foreign net operating loss carryforwards, a significant portion of which carry forward for an indefinite period.

The Company is subject to taxation in the United States, state jurisdictions and foreign jurisdictions. Significant judgment is required in determining the worldwide provision for income taxes and recording the related income tax assets and liabilities. The Company recognizes the financial statement benefit of a tax position only after determining that the relevant tax authority would more-likely-than-not sustain the position following an audit. For tax positions meeting the more-likely-than-not criterion, the amount recognized in the financial statements is the largest benefit that has a greater than 50 percent likelihood of being realized upon ultimate settlement with the relevant tax authority.

The following table summarizes activity related to the Company's gross unrecognized tax benefits, excluding interest and penalties, from January 1 to December 31, 2014, 2013 and 2012 (in thousands):



	Year Ended December 31,
	2014			2013			2012
Beginning Balance	$	110,305		$	85,481		$	55,127
Increases related to prior year tax positions	5,489			10,494			602
Decreases related to prior year tax positions	(27,875		)	(2,103		)	(790		)
Increases related to current year tax positions	17,348			14,565			29,465
Foreign currency translation	(6,946		)	1,868			1,077
Ending Balance	$	98,321		$	110,305		$	85,481

The total amount of unrecognized tax benefits as of December 31, 2014, 2013 and 2012 that, if recognized, would affect the effective tax rate are $72.3 million, $80.0 million, and $39.3 million, respectively.

The Company recognized $1.1 million, $3.3 million and $2.3 million of interest and penalties within "Provision for income taxes" on its consolidated statements of operations for the years ended December 31, 2014, 2013 and 2012, respectively. Total accrued interest and penalties as of December 31, 2014 and 2013 was $5.7 million and $5.3 million, respectively, and were included in "Other non-current liabilities."

The Company is currently under IRS audit for the 2011 and 2012 tax years. Additionally, the Company is currently under audit by several foreign jurisdictions. It is likely that the examination phase of some of these audits will conclude in the next 12 months. The tax years 2009 to 2013 remain open to examination by the major taxing jurisdictions in which the Company is subject to tax. For the year ended December 31, 2014, the Company decreased its liabilities for uncertain tax positions and income tax expense by $21.0 million and $16.7 million, respectively, due to the expiration of the applicable statute of limitations in a foreign jurisdiction. For the year ended December 31, 2014, the Company also decreased its liabilities for uncertain tax positions and income tax expense by $7.7 million as a result of new information that impacted its estimate of the amount that is more-likely-than-not of being realized upon ultimate settlement of a tax position. As of December 31, 2014, the Company believes that it is reasonably possible that additional changes of up to $15.6 million in unrecognized tax benefits may occur within the next 12 months.

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, 2014, no provision has been made for U.S. income taxes and foreign withholding taxes related to the undistributed earnings of the Company's foreign subsidiaries of approximately $271.1 million, because those undistributed earnings are indefinitely reinvested outside the United States. The actual U.S. tax cost would depend on income tax laws and circumstances at the time of distribution. Determination of the amount of unrecognized U.S. deferred tax liability related to the undistributed earnings of the Company's foreign subsidiaries is not practical due to the complexities associated with the calculation.

As of December 31, 2014, the unamortized tax effects of intercompany transactions of $14.2 million is included within "Prepaid expenses and other current assets" on the consolidated balance sheet. As of December 31, 2013, unamortized tax effects of intercompany transactions of $28.5 million and $20.4 million are included within "Prepaid expenses and other current assets" and "Other non-current assets," respectively, on the consolidated balance sheet. As of December 31, 2014, the estimated future amortization of the tax effects of intercompany transactions to income tax expense is $14.2 million for 2015. This amount excludes the benefits, if any, for tax deductions in other jurisdictions that the Company may be entitled to as a result of the related intercompany transactions.