The Company's pre-tax income from continuing operations before equity in earnings of equity method investees consisted of approximately $1.9 billion, $1.1 billion and $0.9 billion from U.S. operations and pre-tax (loss) income of $(7) million, $15 million and $(1) million from foreign operations for the years ended December 31, 2020, 2019 and 2018, respectively.

As a result of the Tax Cuts and Jobs Act, the Company changed its assertion that it intends to indefinitely reinvest undistributed earnings from certain non-U.S. subsidiaries outside the U.S. The Company is indefinitely reinvested in the remaining basis difference and it is not practicable to determine the associated amount of unrecognized deferred tax liability.


	2020		2019		2018
Current:
Federal	$	300	$	176	$	82
State and local	74		53		26
Foreign	1		3		1
Deferred:
Federal	55		21		66
State and local	29		(4)		10
Foreign	1		(2)		(3)
Total	$	460	$	247	$	182


	2020		2019		2018

Tax provision at statutory rate	21.0	%	21.0	%	21.0	%
State and local income taxes, net of federal benefit	4.5		4.6		4.7




Impact of noncontrolling interests	(0.9)		(1.1)		(1.4)

Excess tax benefits on stock-based compensation arrangements	(1.2)		(1.2)		(1.9)
Return to provision true-ups	(0.7)		(1.4)		(1.4)

Change in accounting method	—		—		(1.6)
Impact of equity earnings	0.8		1.1		1.0
Changes in reserves for uncertain tax positions	0.9		1.7		(0.8)
Change in valuation allowances associated with certain net operating losses	0.2		(1.1)		—
Other, net	(0.1)		(0.6)		0.1
Effective tax rate	24.5	%	23.0	%	19.7	%

For the year ended December 31, 2019, the Company recognized a $12 million net income tax benefit due to the release of valuation allowances associated with certain net operating loss carryforwards. In 2018, the Company filed for a tax return accounting method change, effective for the tax year ending December 31, 2017, to accelerate the deduction of certain expenses on its 2017 tax return at the higher 2017 federal corporate statutory income tax rate, resulting in a $15 million income tax benefit. The net income tax benefit associated with changes in reserves for uncertain tax positions in 2018 was primarily related to the expiration of the statute of limitations for certain income tax returns.


	2020		2019
Non-current deferred tax assets (liabilities):
Accounts receivable reserves	$	71	$	64
Liabilities not currently deductible	146		126
Stock-based compensation	47		35

Basis differences in investments, joint ventures and subsidiaries	(81)		(80)
Net operating loss carryforwards, net of valuation allowance	61		75
Operating lease right-of-use assets	(151)		(129)
Operating lease liabilities	161		139
Depreciation and amortization	(604)		(494)
Total non-current deferred tax liabilities, net	$	(350)	$	(264)

The non-current deferred tax assets (liabilities) disclosure at December 31, 2019 has been adjusted to separately state the gross deferred tax right-of-use asset and related gross deferred tax lease liability recognized in accordance with the new accounting standard for leases adopted on January 1, 2019. As of December 31, 2020 and 2019, non-current deferred tax liabilities of $350 million and $264 million, respectively, are included in other liabilities in the consolidated balance sheet.

As of December 31, 2020, the Company had estimated net operating loss carryforwards for federal and state income tax purposes of $60 million and $1.0 billion, respectively, which expire at various dates through 2040. Estimated net operating loss carryforwards for foreign income tax purposes are $76 million as of December 31, 2020, some of which can be carried forward indefinitely while others expire at various dates through 2040. As of December 31, 2020 and 2019, deferred tax assets associated with net operating loss carryforwards of $94 million and $101 million, respectively, have each been reduced by valuation allowances of $33 million and $26 million, respectively.

Income taxes payable, including those classified as long-term in other liabilities in the consolidated balance sheet as of December 31, 2020 and 2019, were $135 million and $113 million, respectively. Prepaid income taxes were $2 million and $3 million as of December 31, 2020 and 2019, respectively, and were recorded in prepaid expenses and other current assets in the consolidated balance sheet.


	2020		2019		2018

Balance, beginning of year	$	88	$	107	$	115
Additions:
For tax positions of current year	2		2		2
For tax positions of prior years	25		16		11
Reductions:
Changes in judgment	(9)		(3)		(6)
Expirations of statutes of limitations	(4)		(2)		(15)
Settlements	(9)		(32)		—
Balance, end of year	$	93	$	88	$	107

The contingent liabilities for tax positions primarily relate to uncertainties associated with the realization of tax benefits derived from the allocation of income and expense among state jurisdictions, the characterization and timing of certain tax deductions associated with business combinations, certain tax credits and the deductibility of certain expenses and settlement payments.

The total amount of unrecognized tax benefits as of December 31, 2020, that, if recognized, would affect the effective income tax rate is $75 million. Based upon the expiration of statutes of limitations, settlements and/or the conclusion of tax examinations, the Company believes it is reasonably possible that the total amount of unrecognized tax benefits may decrease by up to $15 million within the next twelve months.

Accruals for interest expense on contingent tax liabilities are classified in income tax expense in the consolidated statements of operations. Accruals for penalties have historically been immaterial. Interest expense included in income tax expense in each of the years ended December 31, 2020, 2019 and 2018 was approximately $6 million, $5 million and $1 million, respectively. As of December 31, 2020 and 2019, the Company had approximately $21 million and $17 million, respectively, accrued, net of the benefit of a federal and state deduction, for the payment of interest on uncertain tax positions.

The recognition and measurement of certain tax benefits includes estimates and judgment by management and inherently involves subjectivity. Changes in estimates may create volatility in the Company's effective tax rate in future periods and may be due to settlements with various tax authorities (either favorable or unfavorable), the expiration of the statute of limitations on certain tax positions and obtaining new information about particular tax positions that may cause management to change its estimates.

In the regular course of business, various federal, state, local and foreign tax authorities conduct examinations of the Company's income tax filings and the Company generally remains subject to examination until the statute of limitations expires for the respective jurisdiction. The Internal Revenue Service has either completed its examinations of the Company's consolidated federal income tax returns or the statute of limitations has expired up through and including the 2016 tax year. At this time, the Company does not believe that there will be any material additional payments beyond its recorded contingent liability reserves that may be required as a result of these tax audits. As of December 31, 2020, a summary of the tax years that remain subject to examination, awaiting approval, are under appeal, or are otherwise unresolved for the Company's major jurisdictions are: