The liabilities for income taxes reflected in our Consolidated Balance Sheets are as follows (in millions).

	December 31,
	2020			2019
Currently payable (receivable)	$	(276	)	$	24
Deferred		73,261			65,823
Other		1,113			952
	$	74,098		$	66,799

The tax effects of temporary differences that give rise to significant portions of deferred tax assets and deferred tax liabilities are shown below (in millions).

	December 31,
	2020			2019
Deferred tax liabilities:
Investments – unrealized appreciation and cost basis differences	$	40,181		$	32,134
Deferred charges reinsurance assumed		2,613			2,890
Property, plant and equipment and equipment held for lease		30,203			29,388
Goodwill and other intangible assets		6,753			7,293
Other		3,736			3,144
		83,486			74,849
Deferred tax assets:
Unpaid losses and loss adjustment expenses		(1,135	)		(1,086	)
Unearned premiums		(900	)		(853	)
Accrued liabilities		(2,193	)		(1,981	)
Regulatory liabilities		(1,421	)		(1,610	)
Other		(4,576	)		(3,496	)
		(10,225	)		(9,026	)
Net deferred tax liability	$	73,261		$	65,823

We have not established deferred income taxes on accumulated undistributed earnings of certain foreign subsidiaries, which are expected to be reinvested indefinitely. Repatriation of all accumulated earnings of foreign subsidiaries would be impracticable to the extent that such earnings represent capital to support normal business operations. Generally, no U.S. federal income taxes will be imposed on future distributions of foreign earnings under current law. However, distributions to the U.S. or other foreign jurisdictions could be subject to withholding and other local taxes.

On December 22, 2017, legislation known as the Tax Cuts and Jobs Act of 2017 (“TCJA”) was enacted. Among its provisions, the TCJA reduced the statutory U.S. Corporate income tax rate from 35% to 21% effective January 1, 2018 and provided for a one-time tax on certain accumulated undistributed post-1986 earnings of foreign subsidiaries. These effects were largely recorded in 2017 upon the enactment. In 2018, we reduced our estimate of the income taxes on the deemed repatriation of earnings of foreign subsidiaries and recognized additional deferred income tax rate change effects.

Income tax expense reflected in our Consolidated Statements of Earnings for each of the three years ending December 31, 2020 is as follows (in millions).

	2020		2019		2018
Federal	$	10,596	$	19,069	$	(1,613	)
State		1,086		625		175
Foreign		758		1,210		1,117
	$	12,440	$	20,904	$	(321	)

Current	$	5,052	$	5,818	$	5,176
Deferred		7,388		15,086		(5,497	)
	$	12,440	$	20,904	$	(321	)

Income tax expense is reconciled to hypothetical amounts computed at the U.S. federal statutory rate for each of the three years ending December 31, 2020 in the table below (in millions).

	2020			2019			2018
Earnings before income taxes	$	55,693		$	102,696		$	4,001

Hypothetical income tax expense computed at the U.S. federal statutory rate	$	11,696		$	21,566		$	840
Dividends received deduction and tax-exempt interest		(448	)		(433	)		(393	)
State income taxes, less U.S. federal income tax benefit		858			494			138
Foreign tax rate differences		13			(6	)		271
U.S. income tax credits		(1,519	)		(942	)		(711	)
Net benefit from the enactment of the TCJA		—			—			(302	)
Goodwill impairments		1,977			20			21
Other differences, net		(137	)		205			(185	)
	$	12,440		$	20,904		$	(321	)
Effective income tax rate		22.3	%		20.4	%		(8.0	)%

We file income tax returns in the United States and in state, local and foreign jurisdictions. We have settled income tax liabilities with the U.S. federal taxing authority (“IRS”) for tax years through 2011 and the tax years 2012 and 2013 remain open. The IRS is auditing Berkshire’s consolidated U.S. federal income tax returns for the 2014 through 2016 tax years. We are also under audit or subject to audit with respect to income taxes in many state and foreign jurisdictions. It is reasonably possible that certain of these income tax examinations will be settled in 2021. We currently do not believe that the outcome of unresolved issues or claims will be material to our Consolidated Financial Statements.

At December 31, 2020 and 2019, net unrecognized tax benefits were $1,113 million and $952 million, respectively. Included in the balance at December 31, 2020, were $920 million of tax positions that, if recognized, would impact the effective tax rate. The remaining balance in net unrecognized tax benefits principally relates to tax positions where the ultimate recognition is highly certain but there is uncertainty about the timing of recognition. Because of the impact of deferred income tax accounting, these positions, when recognized, would not affect the annual effective income tax rate. We recorded income tax expense of $60 million in 2020 and $377 million in 2019 for uncertain tax positions related to investments by a subsidiary in certain tax equity investment funds that generated income tax benefits from 2015 through 2018. We now believe that it is more likely than not those income tax benefits are not valid. We do not expect any material increases to the estimated amount of unrecognized tax benefits during 2021.