Beginning in the taxable year ended December 31, 2012, the Company has filed, and intends to continue to file, U.S. federal income tax returns as a REIT, and its domestic TRSs filed, and intend to continue to file, separate tax returns as required. The Company also files tax returns in various states and countries. The Company’s state tax returns reflect different combinations of the Company’s subsidiaries and are dependent on the connection each subsidiary has with a particular state and form of organization. The following information pertains to the Company’s income taxes on a consolidated basis.

The income tax provision from continuing operations consisted of the following:



	Year Ended December 31,
	2019			2018			2017
Current:
Federal	$	(1.7	)	$	(1.4	)	$	(0.1	)
State	(5.0		)	(1.8		)	(3.8		)
Foreign	(48.2		)	(189.7		)	(113.4		)
Deferred:
Federal	1.4			4.0			0.2
State	0.5			0.7			1.0
Foreign	53.2			298.3			85.4
Income tax benefit (provision)	$	0.2		$	110.1		$	(30.7	)

The effective tax rate (“ETR”) on income from continuing operations for the years ended December 31, 2019, 2018 and 2017 differs from the federal statutory rate primarily due to the Company’s qualification for taxation as a REIT, as well as adjustments for state and foreign items. As a REIT, the Company may deduct earnings distributed to stockholders against the income generated by its REIT operations. In addition, the Company is able to offset certain income by utilizing its NOLs, subject to specified limitations.

In 2019, there was an income tax law change in India that allows companies to elect into an optional concessional tax regime. The new regime allows for a lower effective tax rate from approximately 35% to approximately 25% and no minimum

alternative tax, while disallowing the benefit of the minimum alternative tax credits. As a result, the Company recorded a tax benefit of $113.0 million for the year ended December 31, 2019.

In 2018, the income tax benefit was attributable to impairment charges and accelerated amortization on intangible assets taken in India as well as a benefit of $85.7 million related to the restructuring of international operations in certain jurisdictions. These benefits were partially offset by the receipt of the payment related to the Tata settlement.

In 2015, there was an income tax law change in Ghana that disallowed unused capital allowances to be carried into 2016, which resulted in a charge to income tax expense for the year ended December 31, 2015. In 2017, the Ghana Revenue Authority issued Practice Note Number DT/2016/010 (the “Practice Note”), which clarified the Capital Allowance section of the Income Tax Act of 2015. The Practice Note allowed for unused Capital Allowance from 2015 to be treated as a deduction in 2016. As a result, the Company recorded a tax benefit of $17.8 million for the year ended December 31, 2017.

The December 2017 legislation commonly referred to as the Tax Cuts and Jobs Act (the “Tax Act”) significantly changed how the U.S. taxes corporations. The Tax Act contained several key provisions including, among other things, a reduction in the corporate income rate from 35% to 21% for tax years beginning after December 31, 2017. As a result of this change in tax rate, the rate at which the Company’s deferred tax assets of the Company’s TRSs decreased, resulting in additional tax expense of $2.4 million, which did not significantly impact the Company's effective tax rate.

Reconciliation between the U.S. statutory rate and the effective rate from continuing operations is as follows:



	Year Ended December 31,
	2019		2018		2017
Statutory tax rate	21	%	21	%	35	%
Adjustment to reflect REIT status (1)	(21	)	(21	)	(35	)
Foreign taxes	3		(8	)	1
Foreign withholding taxes	3		4		3
Uncertain tax positions	1		—		—
Changes in tax laws	(6	)	—		(2	)
Impact from restructuring	(1	)	(6	)	—
Effective tax rate	(0	)%	(10	)%	2	%

The domestic and foreign components of income from continuing operations before income taxes are as follows:



	Year Ended December 31,
	2019		2018			2017
United States	$	1,527.0	$	1,212.7		$	971.2
Foreign	389.4		(58.1		)	284.9
Total	$	1,916.4	$	1,154.6		$	1,256.1

The components of the net deferred tax asset and liability and related valuation allowance were as follows:



	December 31, 2019			December 31, 2018
Assets:
Operating lease liability	$	878.5		$	—
Net operating loss carryforwards	356.6			264.9
Accrued asset retirement obligations	174.9			165.7
Stock-based compensation	5.6			6.3
Unearned revenue	31.7			28.3
Unrealized loss on foreign currency	3.8			12.9
Other accruals and allowances	65.6			78.6
Items not currently deductible and other	26.1			26.2
Liabilities:
Depreciation and amortization	(1,040.3		)	(757.0		)
Right-of-use asset	(865.1		)	—
Deferred rent	(79.7		)	(36.9		)
Other	—			(15.3		)
Subtotal	(442.3		)	(226.3		)
Valuation allowance	(194.2		)	(151.9		)
Net deferred tax liabilities	$	(636.5	)	$	(378.2	)

The Company provides valuation allowances if, based on the available evidence, it is more likely than not that some or all of the deferred tax assets will not be realized. Management assesses the available evidence to estimate if sufficient future taxable income will be generated to use the existing deferred tax assets.

At December 31, 2019 and 2018, the Company has provided a valuation allowance of $194.2 million and $151.9 million, respectively, which primarily relates to foreign items. The increase in the valuation allowance for the year ending December 31, 2019 is due to uncertainty as to the timing of, and the Company’s ability to recover, net deferred tax assets in certain foreign operations in the foreseeable future, offset by fluctuations in foreign currency exchange rates. The amount of deferred tax assets considered realizable, however, could be adjusted if objective evidence in the form of cumulative losses is no longer present and additional weight may be given to subjective evidence such as the Company’s projections for growth.

A summary of the activity in the valuation allowance is as follows:



	2019			2018			2017
Balance as of January 1,	$	151.9		$	142.0		$	144.4
Additions (1)	42.5			15.7			11.6
Reversals	—			—			(9.1		)
Foreign currency translation	(0.2		)	(5.8		)	(4.9		)
Balance as of December 31,	$	194.2		$	151.9		$	142.0

The recoverability of the Company’s deferred tax assets has been assessed utilizing projections based on its current operations. Accordingly, the recoverability of the deferred tax assets is not dependent on material asset sales or other non-routine transactions. Based on its current outlook of future taxable income during the carryforward period, the Company believes that deferred tax assets, other than those for which a valuation allowance has been recorded, will be realized.

Despite a mandatory one-time inclusion in U.S. taxable income of accumulated earnings of foreign subsidiaries under the Tax Act for the year ended December 31, 2017, the Company intends to continue to reinvest foreign earnings indefinitely outside of the U.S. and does not expect to incur any significant additional taxes, including withholding taxes, related to such amounts.

At December 31, 2019, the Company had net federal, state and foreign operating loss carryforwards available to reduce future taxable income. If not utilized, the Company’s NOLs expire as follows:



Years ended December 31,	Federal		State		Foreign
2020 to 2024	$	—	$	222.3	$	11.9
2025 to 2029	141.6		285.7		104.8
2030 to 2034	7.0		41.4		19.6
2035 to 2039	3.6		159.5		—
Indefinite carryforward	22.8		—		853.8
Total	$	175.0	$	708.9	$	990.1

As of December 31, 2019 and 2018, the total amount of unrecognized tax benefits that would impact the ETR, if recognized, is $158.1 million and $93.7 million, respectively. The amount of unrecognized tax benefits for the year ended December 31, 2019 includes additions to the Company’s existing tax positions of $72.0 million, which includes $63.6 million related to the Eaton Towers Acquisition.

The Company expects the unrecognized tax benefits to change over the next 12 months if certain tax matters ultimately settle with the applicable taxing jurisdiction during this timeframe, or if the applicable statute of limitations lapses. The impact of the amount of such changes to previously recorded uncertain tax positions could range from zero to $53.0 million.

A reconciliation of the beginning and ending amount of unrecognized tax benefits are as follows:



	Year Ended December 31,
	2019			2018			2017
Balance at January 1	$	107.7		$	116.7		$	107.6
Additions based on tax positions related to the current year	33.3			8.1			7.6
Additions and reductions for tax positions of prior years	37.5			0.3			—
Foreign currency	(1.6		)	(8.1		)	1.9
Reduction as a result of the lapse of statute of limitations	(1.3		)	(2.6		)	(0.4		)
Reduction as a result of effective settlements	—			(6.7		)	—
Balance at December 31	$	175.6		$	107.7		$	116.7

During the years ended December 31, 2019, 2018 and 2017, the statute of limitations on certain unrecognized tax benefits lapsed and certain positions were effectively settled, which resulted in a decrease of $2.5 million, $9.3 million and $0.4 million, respectively, in the liability for uncertain tax benefits.

The Company recorded penalties and tax-related interest expense to the tax provision of $10.3 million, $8.0 million and $5.0 million for the years ended December 31, 2019, 2018 and 2017, respectively. In addition, due to the expiration of the statute of limitations in certain jurisdictions and certain positions that were effectively settled, the Company reduced its liability for penalties and income tax-related interest expense related to uncertain tax positions during the years ended December 31, 2019, 2018 and 2017 by $2.7 million, $16.2 million and $0.6 million, respectively.

As of December 31, 2019 and 2018, the total amount of accrued income tax-related interest and penalties included in the consolidated balance sheets were $26.6 million and $19.1 million, respectively.

The Company has filed for prior taxable years, and for its taxable year ended December 31, 2019 will file, numerous consolidated and separate income tax returns, including U.S. federal and state tax returns and foreign tax returns. The Company is subject to examination in the U.S. and various state and foreign jurisdictions for certain tax years. As a result of the Company’s ability to carryforward federal, state and foreign NOLs, the applicable tax years generally remain open to examination several years after the applicable loss carryforwards have been used or have expired. The Company regularly assesses the likelihood of additional assessments in each of the tax jurisdictions resulting from these examinations. The Company believes that adequate provisions have been made for income taxes for all periods through December 31, 2019.