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INCOME TAXES (Tables)
12 Months Ended
Dec. 31, 2022
Income Tax Disclosure [Abstract]  
Schedule of Loss from Continuing Operations
The components of our Loss from continuing operations before income tax by geography for the years ended December 31, 2022, 2021 and 2020 are as follows (in thousands):
202220212020
U.S.$(2,429,315)$4,792,852 $(375,262)
International(458,787)(5,339,455)348,744 
Total loss from continuing operations before income tax$(2,888,102)$(546,603)$(26,518)
Schedule of Components of Income Tax Expense (Benefit)
Income tax from continuing operations consists of the following for the years ended December 31, 2022, 2021 and 2020 (in thousands):
202220212020
Current:
U.S. Federal$21,057 $13,649 $(108,866)
U.S. State1,731 1,491 (434)
International6,031 10,495 (1,124)
Total current income tax$28,819 $25,635 $(110,424)
Deferred:
U.S. Federal$(622)$118 $(143,411)
U.S. State1,065 (564)(11,773)
International(7,746)(2,711)(8,374)
Total deferred income tax$(7,303)$(3,157)$(163,558)
Total income tax$21,516 $22,478 $(273,982)
Schedule of Reconciliation of Income Tax
A reconciliation of income tax from continuing operations at the U.S. federal statutory income tax rate to the total income tax provision from continuing operations for the years ended December 31, 2022, 2021 and 2020 is as follows (in thousands):
202220212020
Notional U.S. federal income tax provision at the statutory rate$(606,502)$(114,787)$(5,569)
State income tax, net of federal benefit(9,517)6,750 (17,311)
U.S. tax reform impact— — (129,599)
Uncertain tax positions21,930 42,415 35,941 
Residual tax on non-U.S. net earnings(32,257)(181,739)(83,550)
Non-deductible goodwill impairment385,459 76,230 7,490 
Change in valuation allowance306,497 495,565 (97,752)
Base erosion minimum tax— — 77,438 
Non-deductible expenses47,221 39,791 8,875 
Executive compensation limitation5,580 6,215 5,857 
Equity based compensation3,247 2,695 6,495 
Financing activities (1)73,629 (287,012)(33,217)
Investment activities (2)(178,018)(68,943)(44,964)
Other4,247 5,298 (4,116)
Income tax$21,516 $22,478 $(273,982)
__________
(1)The amount in 2022 primarily relates to non-deductible foreign currency adjustments on intercompany debt. The amount in 2021 primarily relates to a net tax benefit of approximately $1.2 billion related to non-taxable intercompany cancellation of indebtedness income, which was partially offset by a net tax expense of approximately $465 million related to non-deductible bad debt expense and a net tax expense of approximately $427 million related to non-deductible intercompany interest expense. The net tax benefit is fully offset by an increase to the valuation allowance.
(2)The amounts in 2022 and 2021 primarily relate to tax deductible losses associated with the investment in consolidated subsidiaries. The tax benefit is fully offset by an increase to the valuation allowance.
Schedule of Deferred Income Taxes
Deferred income taxes result from temporary differences between the amount of assets and liabilities recognized for financial reporting and tax purposes. The significant components of the net deferred income tax liability shown on the balance sheets as of December 31, 2022 and 2021 are as follows (in thousands):
December 31, 2022December 31, 2021
Deferred tax assets:
Accrued expenses and reserves$220,415 $144,573 
Deferred interest deduction421,552 347,501 
Fixed assets, intangible assets and deferred amortization560,257 512,584 
Loss on capital assets23,511 64,503 
Net operating loss carryforward9,214,688 9,258,122 
Other49,943 50,694 
Research and development and other tax credit carryforwards7,777 8,254 
Total gross deferred income tax assets$10,498,143 $10,386,231 
Deferred tax liabilities:
Other$(3,156)$(8,586)
Investments(107)(124,311)
Intercompany notes(72,286)(104,530)
Total gross deferred income tax liabilities$(75,549)$(237,427)
Valuation allowance(10,436,419)(10,169,294)
Net deferred income tax liability$(13,825)$(20,490)
Schedule of Tax Credit Carryforwards
As of December 31, 2022, the Company had significant deferred tax assets for tax credits, net operating and capital loss carryforwards, net of unrecognized tax positions, as presented below (in thousands):
JurisdictionAmountBegin to Expire
Ireland$79,617 Indefinite
Luxembourg$8,934,046 2034
U.S.:
Federal-ordinary losses$19,105 2037
Federal-capital losses$13,699 2023
Federal-tax credits$14,081 2025
State-ordinary losses$227,587 2023
State-capital losses$11,871 2023
State-tax credits$3,256 2037
Schedule of Valuation Allowance
As of December 31, 2022, the Company had the following significant valuation allowances (in thousands):
JurisdictionDecember 31, 2022
Ireland$289,500 
Luxembourg$8,862,060 
U.S.$1,278,026 
Schedule of Unrecognized Tax Benefits Roll Forward The following table summarizes the activity related to UTPs during the years ended December 31, 2022, 2021 and 2020 (in thousands):
Unrecognized Tax Positions Federal, State and Foreign Tax
UTP Balance at December 31, 2019$486,481 
Gross additions for current year positions33,402 
Gross reductions for prior period positions(577)
Gross additions for prior period positions16,914 
Decrease due to lapse of statute of limitations(7,033)
Currency translation adjustment588 
UTP Balance at December 31, 2020$529,775 
Gross additions for current year positions36,662 
Gross reductions for prior period positions(702)
Gross additions for prior period positions1,203 
Decrease due to lapse of statute of limitations(475)
Currency translation adjustment(24)
UTP Balance at December 31, 2021$566,439 
Gross additions for current year positions20,061 
Decrease due to lapse of statute of limitations(4,451)
Currency translation adjustment(2,419)
UTP Balance at December 31, 2022$579,630 
Accrued interest and penalties66,736 
Total UTP balance including accrued interest and penalties$646,366 
Schedule of Income Tax Examinations
As of December 31, 2022, we may be subject to examination in the following major tax jurisdictions:
JurisdictionOpen Years
Canada2016 through 2022
India2012 through 2022
Ireland2016 through 2022
Luxembourg2015 through 2022
U.S. - federal, state and local2006 through 2022