INCOME TAXES (Tables)

12 Months Ended

Dec. 31, 2023

Components of (Losses) Earnings Before Income Taxes

The components of our earnings before income taxes for the last three fiscal years consisted of:


(in millions)	2023		2022		2021
U.S.	$	2,113	$	2,268	$	890
Non-U.S.	1,265		846		290
	$	3,378	$	3,114	$	1,180

Provision (Benefit) for Income Taxes

Our (provision) benefit for income taxes for the last three fiscal years consisted of:


(in millions)		2023		2022		2021
Current	-U.S. Federal	$	(431)	$	(364)	$	99
	-U.S. State	(158)		(82)		24
	-Non-U.S.	(249)		(155)		(86)
		(838)		(601)		37

Deferred	-U.S. Federal	94		(129)		(122)
	-U.S. State	16		(25)		(37)
	-Non-U.S.	433		(1)		41
		543		(155)		(118)
		$	(295)	$	(756)	$	(81)

Unrecognized Tax Benefits Reconciliation

The following table reconciles our unrecognized tax benefit balance for each year from the beginning of 2021 to the end of 2023:


(in millions)	Amount
Unrecognized tax benefit at beginning of 2021	$	464

Change attributable to tax positions taken in prior years	(134)
Change attributable to tax positions taken during the current period	—
Decrease attributable to settlements with taxing authorities	(48)

Unrecognized tax benefit at year-end 2021	282
Change attributable to tax positions taken in prior years	(15)
Change attributable to tax positions taken during the current period	3
Decrease attributable to settlements with taxing authorities	(15)

Unrecognized tax benefit at year-end 2022	255
Change attributable to tax positions taken in prior years	(90)
Change attributable to tax positions taken during the current period	16
Decrease attributable to settlements with taxing authorities	(9)

Unrecognized tax benefit at year-end 2023	$	172

Schedule of Deferred Tax Assets and Liabilities

The following table presents the tax effect of each type of temporary difference and carry-forward that gave rise to significant portions of our deferred tax assets and liabilities as of year-end 2023 and year-end 2022:


(in millions)	At Year-End 2023		At Year-End 2022
Deferred Tax Assets
Employee benefits	$	265	$	243
Net operating loss carry-forwards	1,132		1,096
Accrued expenses and other reserves	219		181

Tax credits	64		55
Loyalty Program	277		168
Deferred income	102		66
Lease liabilities	266		304
Interest limitation	67		187
Other	40		12
Deferred tax assets	2,432		2,312
Valuation allowance	(1,149)		(1,359)
Deferred tax assets after valuation allowance	1,283		953
Deferred Tax Liabilities

Property and equipment	(62)		(58)
Intangibles	(471)		(626)
Right-of-use assets	(248)		(265)
Self-insurance	(22)		(37)
Other	(16)		(40)
Deferred tax liabilities	(819)		(1,026)
Net deferred taxes	$	464	$	(73)

Reconciliation of the U.S. Statutory Tax Rate to Effective Income Tax Rate

The following table reconciles the U.S. statutory tax rate to our effective income tax rate for the last three fiscal years:


	2023		2022		2021
U.S. statutory tax rate	21.0	%	21.0	%	21.0	%
U.S. state income taxes, net of U.S. federal tax benefit	2.8		2.8		2.7
Non-U.S. income	0.3		(0.5)		(0.5)
Change in valuation allowance	(5.8)		0.4		(0.7)
Change in uncertain tax positions	(2.3)		0.3		(12.0)




Excess tax benefits related to equity awards	(0.8)		(0.7)		(2.8)
U.S. tax on foreign earnings	1.1		0.2		0.4
Intellectual property restructuring	(7.9)		0.0		0.0
Other, net	0.3		0.8		(1.3)
Effective rate	8.7	%	24.3	%	6.8	%