Income Taxes

12 Months Ended

Dec. 31, 2020

Income Tax Disclosure [Abstract]

Income Taxes

Income Taxes

Reconciliations of the statutory U.S. federal income tax rates to our effective tax rate for continuing operations follow:

	Years Ended December 31,
	2020		2019		2018
Statutory rate	21.0	%	21.0	%	21.0	%
State tax, net of federal benefit	2.9		3.9		3.8
Business tax credits	(2.2)		(3.5)		(0.5)
Reverse federal impact of indemnification adjustments	0.2		0.3		3.5
Unrecognized tax benefits, U.S. federal and state, net of federal benefit	0.7		(0.1)		(15.9)
Other, net	1.1		0.7		1.0
Effective tax rate	23.7	%	22.3	%	12.9	%

The effective tax rate varies from the statutory U.S. federal rate of 21 percent primarily due to business tax credits and the impact of state taxes, net of federal benefit, for the year ended December 31, 2020 and 2019, respectively; and the reduction in uncertain tax positions related to statute of limitation expirations and the impact of state taxes, net of federal benefit, for the year ended December 31, 2018.

Income tax expense consists of:

	December 31,
	2020		2019		2018
Current provision:
Federal	$	172,153	$	150,800	$	102,516
State	28,387		24,378		32,638
Total current provision	200,540		175,178		135,154
Deferred benefit:
Federal	58,003		(8,240)		(57,076)
State	14,773		(1,474)		(6,225)
Total deferred benefit	72,776		(9,714)		(63,301)
Provision for income tax expense	$	273,316	$	165,464	$	71,853

The tax effect of temporary differences that give rise to deferred tax assets and liabilities is summarized below.

	December 31,
	2020		2019
Deferred tax assets:
Loan reserves	$	356,296	$	109,369
Stock-based compensation plans	10,914		10,022
Deferred revenue	1,441		1,017
Operating loss carryovers	83		—
Accrued expenses not currently deductible	13,139		12,599
Net unrealized losses	9,047		2,124
Unrecorded tax benefits	6,997		6,049
Market value adjustments on student loans, investments and derivatives	—		—
Other	1,003		874
Total deferred tax assets	398,920		142,054
Deferred tax liabilities:
Fixed assets	11,098		10,475
Acquired intangible assets	7,767		5,453
Market value adjustments on student loans, investments and derivatives	5,651		3,175
Net unrealized gains	—		—
Federal deferred for state receivable	7,456		5,368
Student loan premiums and discounts, net	11,336		3,398
Other	307		285
Total deferred tax liabilities	43,615		28,154
Net deferred tax assets	$	355,305	$	113,900

Included in operating loss carryovers are state net operating losses of $277 million and $6 million as of December 31, 2020 and 2019, respectively. The Company has recorded a valuation allowance against these net operating losses of $277 million and $6 million, respectively. Also included in operating loss carryovers is a capital loss of $16 million and $0 as of December 31, 2020 and 2019, respectively. The Company has recorded a full valuation allowance against this capital loss. The valuation allowance is primarily attributable to deferred tax assets for state net operating losses and capital losses that management believes is more likely than not to expire prior to being realized.

The ultimate realization of the deferred tax assets is dependent upon the generation of future taxable income of the appropriate character (i.e., capital or ordinary) during the period in which the temporary differences become deductible. Management considers, among other things, the scheduled reversals of deferred tax liabilities and the history of positive taxable income in evaluating the realizability of the deferred tax assets. Management believes that it is more likely than not that the results of future operations will generate sufficient taxable income to realize our deferred tax assets (other than state net operating loss and capital loss carryovers as outlined above).

As of December 31, 2020, the state net operating loss carryforwards will begin to expire in 2029 and the capital loss will expire in 2025.

Accounting for Uncertainty in Income Taxes

The following table summarizes changes in unrecognized tax benefits: 

	December 31,
	2020		2019		2018
Unrecognized tax benefits at beginning of year	$	53,509	$	52,159	$	131,608
Increases resulting from tax positions taken during a prior period	12,723		12,333		4,121
Decreases resulting from tax positions taken during a prior period	(817)		(851)		—
Increases resulting from tax positions taken during the current period	7,815		4,572		3,169
Decreases related to settlements with taxing authorities	(148)		(8,670)		(601)
Reductions related to the lapse of statute of limitations	(9,948)		(6,034)		(86,138)
Unrecognized tax benefits at end of year	$	63,134	$	53,509	$	52,159

As of December 31, 2020, the gross unrecognized tax benefits are $63 million. Included in the $63 million are $56 million of unrecognized tax benefits that, if recognized, would favorably impact the effective tax rate. As a part of the Spin-Off, the Company recorded a liability related to uncertain tax positions for which it is indemnified by Navient. See Note 2, “Significant Accounting Policies — Income Taxes,” for additional details.

Tax related interest and penalty expense is reported as a component of income tax expense. As of December 31, 2020, 2019 and 2018, the total amount of income tax-related accrued interest and penalties, net of related benefit, recognized in the consolidated balance sheets was $11 million, $12 million and $14 million, respectively.

For the years ended December 31, 2020, 2019 and 2018, the total amount of income tax-related accrued interest, net of related tax benefit, recognized in the consolidated statements of income was $(1) million, $(1) million and $(7) million, respectively.

The Company or one of its subsidiaries files income tax returns at the U.S. federal level and in most U.S. states. U.S. federal income tax returns filed for years 2014 and prior are no longer subject to examination. Various combinations of subsidiaries, tax years, and jurisdictions remain open for review, subject to statute of limitations periods (typically 3 to 4 prior years). The Company’s federal income tax return for the year ended December 31, 2015 is currently under audit by the Internal Revenue Service. We do not expect the resolution of open audits to have a material impact on our unrecognized tax benefits.

It is reasonably possible that the uncertain tax position reserve may decrease by as much as $3 million during the next 12 months due to the expiration of statutes of limitations primarily related to indemnified tax liabilities. The reduction in the uncertain tax position reserve would be reflected as a tax benefit. We recorded a tax indemnification receivable from Navient for the indemnified tax liabilities which are included in the uncertain tax position reserve. A portion of the tax benefit will be offset by an expense related to the write-down of the indemnification receivable.