Income Taxes

Income before income tax and the provision for income tax consist of the following (in millions):



Years ended December 31	2015			2014			2013
Income before income taxes:
U.K.	$	149		$	347		$	96
U.S.	(51		)	(55		)	349
Other	1,591			1,473			1,093
Total	$	1,689		$	1,765		$	1,538
Income tax expense (benefit):
Current:
U.K.	$	43		$	1		$	(18	)
U.S. federal	137			156			111
U.S. state and local	54			75			52
Other	256			236			259
Total current tax expense	$	490		$	468		$	404
Deferred tax expense (benefit):
U.K.	$	(39	)	$	38		$	43
U.S. federal	(140		)	(133		)	(48		)
U.S. state and local	(14		)	(24		)	10
Other	(30		)	(15		)	(19		)
Total deferred tax benefit	$	(223	)	$	(134	)	$	(14	)
Total income tax expense	$	267		$	334		$	390

Income before income taxes shown above is based on the location of the business unit to which such earnings are attributable for tax purposes. In addition, because the earnings shown above may in some cases be subject to taxation in more than one country, the income tax provision shown above as U.K., U.S. or Other may not correspond to the geographic attribution of the earnings.

A reconciliation of the income tax provisions based on the Company's domicile and statutory rate at each reporting period is performed. The 2015, 2014 and 2013 reconciliations are based on the U.K. statutory corporate tax rate of 20.3%, 21.5%, and 23.0%, respectively. The reconciliation to the provisions reflected in the Consolidated Financial Statements is as follows:



Years ended December 31	2015	2014	2013
Statutory tax rate	20.3%	21.5%	23.0%
U.S. state income taxes, net of U.S. federal benefit	0.5	1.5	2.6
Taxes on international operations (1)	(6.6)	(8.9)	(4.4)
Nondeductible expenses	2.2	1.7	1.4
Adjustments to prior year tax requirements	(1.3)	0.9	0.1
Deferred tax adjustments, including statutory rate changes	(0.1)	(0.7)	1.4
Deferred tax adjustments, international earnings	—	1.0	3.3
Adjustments to valuation allowances	(0.6)	0.6	(1.7)
Change in uncertain tax positions	1.4	1.7	(0.3)
Other — net	—	(0.4)	—
Effective tax rate	15.8%	18.9%	25.4%

(1)

The Company determines the adjustment for taxes on international operations based on the difference between the statutory tax rate applicable to earnings in each foreign jurisdiction and the enacted rate of 20.3%, 21.5% and 23.0% at December 31, 2015, 2014 and 2013, respectively. The benefit to the Company's effective income tax rate from taxes on international operations relates to benefits from lower-taxed global operations, primarily due to the use of global funding structures.

The components of the Company's deferred tax assets and liabilities are as follows (in millions):



As of December 31	2015			2014
Deferred tax assets:
Employee benefit plans	$	635		$	739
Net operating/capital loss and tax credit carryforwards	349			295
Accrued interest	293			303
Other accrued expenses	98			44
Deferred revenue	65			40
Investment basis differences	56			45
Other	56			6
Total	1,552			1,472
Valuation allowance on deferred tax assets	(175		)	(205		)
Total	$	1,377		$	1,267
Deferred tax liabilities:
Intangibles and property, plant and equipment	$	(961	)	$	(1,058	)
Other accrued expenses	(99		)	(40		)
Deferred costs	(30		)	(28		)
Unrealized foreign exchange gains	(29		)	(44		)
Unremitted earnings	(18		)	(28		)
Other	(44		)	(28		)
Total	$	(1,181	)	$	(1,226	)
Net deferred tax asset	$	196		$	41

Deferred income taxes (assets and liabilities have been netted by jurisdiction) have been classified in the Consolidated Statements of Financial Position as follows (in millions):



As of December 31,	2015			2014
Deferred tax assets — current (1)	$	232		$	212
Deferred tax assets — non-current	141			144
Deferred tax liabilities — current (1)	(1		)	(2		)
Deferred tax liabilities — non-current	(176		)	(313		)
Net deferred tax asset	$	196		$	41


(1)	Included in Other current assets and Other current liabilities.

Valuation allowances have been established primarily with regard to the tax benefits of certain net operating loss, capital loss and interest expense carryforwards. Valuation allowances decreased by $30 million as of December 31, 2015 when compared to December 31, 2014, primarily attributable to the reversal of a valuation allowance and the impact of foreign currency translation.

The Company recognized, as an adjustment to additional paid-in-capital, income tax benefits attributable to employee stock compensation of $126 million, $89 million and $74 million in 2015, 2014 and 2013, respectively.

U.S. deferred income taxes of $20 million were accrued in 2015 on undistributed earnings that are not permanently reinvested. Undistributed earnings of non-U.S. entities were approximately $2.2 billion at December 31, 2015. U.S. income taxes have not been provided on these undistributed earnings because they are considered to be permanently reinvested in those subsidiaries. It is not practicable to estimate the amount of unrecognized deferred tax liabilities, if any, for these undistributed foreign earnings.

At December 31, 2015 and 2014, the Company had U.K. operating loss carryforwards of $449 million and $154 million and capital loss carryforwards of $360 million and $380 million, respectively. In addition, at December 31, 2015 and 2014, the Company had U.S. federal operating loss carryforwards of $7.5 million and $18 million, and U.S. state operating loss carryforwards of $443 million and $451 million, respectively. In other non-U.S. jurisdictions, the Company had operating loss carryforwards of $245 million and $325 million and capital loss carryforwards of $206 million and $223 million as of December 31, 2015 and 2014, respectively. The U.K. operating losses and capital losses have an indefinite carryforward. The federal operating loss carryforwards as of December 31, 2015 expire at various dates from 2020 to 2035 and the state operating loss carryforwards as of December 31, 2015 expire at various dates from 2016 to 2035. Operating and capital losses, in other non-U.S. jurisdictions have various carryforward periods and will begin to expire in 2019.

During 2012, the Company was granted a tax holiday for the period from October 1, 2012 through September 30, 2022, with respect to withholding taxes and certain income derived from services in Singapore. This tax holiday and reduced withholding tax rate may be extended when certain conditions are met or may be terminated early if certain conditions are not met. The benefit realized was approximately $23 million, $7 million, and $3 million during the years ended December 31, 2015, 2014, and 2013, respectively. The impact of this tax holiday on diluted earnings per share was $0.08, $0.02, and $0.01 during the years ended December 31, 2015, 2014, and 2013, respectively.

Uncertain Tax Positions

The following is a reconciliation of the Company's beginning and ending amount of uncertain tax positions (in millions):



	2015			2014
Balance at January 1	$	191		$	164
Additions based on tax positions related to the current year	31			31
Additions for tax positions of prior years	53			10
Reductions for tax positions of prior years	(18		)	(6		)
Settlements	(32		)	—
Business combinations	—			5
Lapse of statute of limitations	(5		)	(11		)
Foreign currency translation	(2		)	(2		)
Balance at December 31	$	218		$	191

The Company's liability for uncertain tax positions as of December 31, 2015, 2014, and 2013, includes $180 million, $154 million, and $141 million, respectively, related to amounts that would impact the effective tax rate if recognized. It is possible that the amount of unrecognized tax benefits may change in the next twelve months; however, we do not expect the change to have a significant impact on our consolidated statements of income or consolidated balance sheets. These changes may be the result of settlements of ongoing audits. At this time, an estimate of the range of the reasonably possible outcomes within the twelve months cannot be made.

The Company recognizes interest and penalties related to uncertain tax positions in its provision for income taxes. The Company accrued potential interest and penalties of $2 million, $4 million, and $2 million in 2015, 2014, and 2013, respectively. The Company recorded a liability for interest and penalties of $33 million, $31 million, and $27 million as of December 31, 2015, 2014, and 2013, respectively.

The Company and its subsidiaries file income tax returns in their respective jurisdictions. The Company has substantially concluded all U.S. federal income tax matters for years through 2007. Material U.S. state and local income tax jurisdiction examinations have been concluded for years through 2005. The Company has concluded income tax examinations in its primary non-U.S. jurisdictions through 2005.