Income Taxes

The following table provides the components of the Company’s provision for income taxes for 2014, 2013 and 2012:



	2014		2013		2012
	(in millions)
Current:
U.S. Federal	$	454	$	407	$	432
U.S. State	69		90		67
Non-U.S.	21		28		18
Total	544		525		517
Deferred:
U.S. Federal	46		11		14
U.S. State	3		3		4
Non-U.S.	1		4		(7		)
Total	50		18		11
Provision for Income Taxes	$	594	$	543	$	528

The non-U.S. component of pre-tax income, arising principally from overseas operations, was income of $152 million, $131 million and $1 million for 2014, 2013 and 2012, respectively. The 2012 income included the impact of the $93 million impairment of goodwill and other intangible assets at La Senza.

The Company's income taxes payable has been reduced by the excess tax benefits from employee stock plan awards. For stock options, the Company receives an excess income tax benefit calculated as the tax effect of the difference between the fair market value of the stock at the time of grant and exercise. For restricted stock, the Company receives an excess income tax benefit calculated as the tax effect of the difference between the fair market value of the stock at the time of grant and vesting. The Company had net excess tax benefits from equity awards of $43 million, $36 million and $116 million in 2014, 2013 and 2012, respectively, which were reflected as increases to equity.

The following table provides the reconciliation between the statutory federal income tax rate and the effective tax rate for 2014, 2013 and 2012:



	2014		2013		2012
Federal Income Tax Rate	35.0	%	35.0	%	35.0	%
State Income Taxes, Net of Federal Income Tax Effect	3.6	%	3.8	%	4.0	%
Impact of Non-U.S. Operations	(1.3	)%	(1.4	)%	1.1	%
Non-deductible Impairment of Goodwill and Other Intangible Assets	—	%	—	%	2.4	%
Other Items, Net	(1.0	)%	0.1	%	(1.3	)%
Effective Tax Rate	36.3	%	37.5	%	41.2	%

Deferred Taxes

The following table provides the effect of temporary differences that cause deferred income taxes as of January 31, 2015 and February 1, 2014. Deferred tax assets and liabilities represent the future effects on income taxes resulting from temporary differences and carryforwards at the end of the respective year.



	January 31, 2015									February 1, 2014
	Assets			Liabilities			Total			Assets			Liabilities			Total
	(in millions)
Leases	$	49		$	—		$	49		$	46		$	—		$	46
Non-qualified Retirement Plan	97			—			97			94			—			94
Property and Equipment	—			(283		)	(283		)	—			(219		)	(219		)
Goodwill	—			(15		)	(15		)	—			(15		)	(15		)
Trade Names and Other Intangibles	—			(139		)	(139		)	—			(139		)	(139		)
State Net Operating Loss Carryforwards	18			—			18			21			—			21
Non-U.S. Operating Loss Carryforwards	158			—			158			161			—			161
Valuation Allowance	(177		)	—			(177		)	(183		)	—			(183		)
Other, Net	79			—			79			71			—			71
Total Deferred Income Taxes	$	224		$	(437	)	$	(213	)	$	210		$	(373	)	$	(163	)

As of January 31, 2015, the Company had available for state income tax purposes net operating loss carryforwards which expire, if unused, in the years 2015 through 2034. The Company has analyzed the realization of the state net operating loss carryforwards on an individual state basis. For those states where the Company has determined that it is more likely than not that the state net operating loss carryforwards will not be realized, a valuation allowance has been provided for the deferred tax asset.

As of January 31, 2015, the Company had available for non-U.S. tax purposes net operating loss carryforwards which expire, if unused, in the years 2027 through 2034. The Company has determined that it is more likely than not that all of the net operating loss carryforwards will not be realized, and a valuation allowance has been provided for the net deferred tax assets, including the net operating loss carryforwards, of the related tax loss entities.

As of January 31, 2015, we have not provided deferred U.S. income taxes on approximately $216 million of undistributed earnings from non-U.S. subsidiaries. Any unrecognized deferred income tax liability resulting from these amounts is not expected to reverse in the foreseeable future; furthermore, the undistributed foreign earnings are permanently reinvested. If the Company elects to distribute these foreign earnings in the future, they could be subject to additional income taxes. Determination of the amount of any unrecognized deferred income tax liability is not practicable because such liability, if any, is dependent on circumstances existing if and when remittance occurs.

Income tax payments were $526 million for 2014, $468 million for 2013 and $336 million for 2012.

Uncertain Tax Positions

The following table summarizes the activity related to the Company’s unrecognized tax benefits for U.S. federal, state & non-U.S. tax jurisdictions for 2014, 2013 and 2012, without interest and penalties:



	2014			2013			2012
	(in millions)
Gross Unrecognized Tax Benefits, as of the Beginning of the Fiscal Year	$	167		$	185		$	146
Increases in Unrecognized Tax Benefits for Prior Years	16			39			13
Decreases in Unrecognized Tax Benefits for Prior Years	(14		)	(54		)	(19		)
Increases in Unrecognized Tax Benefits as a Result of Current Year Activity	36			37			52
Decreases to Unrecognized Tax Benefits Relating to Settlements with Taxing Authorities	(5		)	(34		)	(1		)
Decreases to Unrecognized Tax Benefits as a Result of a Lapse of the Applicable Statute of Limitations	(7		)	(6		)	(6		)
Gross Unrecognized Tax Benefits, as of the End of the Fiscal Year	$	193		$	167		$	185

Of the $193 million, $167 million and $185 million of total unrecognized tax benefits at January 31, 2015, February 1, 2014, and February 2, 2013, respectively, approximately $170 million, $143 million and $160 million, respectively, represent the amount of unrecognized tax benefits that, if recognized, would favorably affect the effective income tax rate in future periods. These amounts are net of the offsetting tax effects from other tax jurisdictions.

Of the total unrecognized tax benefits, it is reasonably possible that $142 million could change in the next 12 months due to audit settlements, expiration of statute of limitations or other resolution of uncertainties. Due to the uncertain and complex application of tax regulations, it is possible that the ultimate resolution of audits may result in amounts which could be different from this estimate. In such case, the Company will record additional tax expense or tax benefit in the period in which such matters are effectively settled.

The Company recognizes interest and penalties related to unrecognized tax benefits as components of income tax expense. The Company recognized interest and penalties expense of $1 million, $4 million and $1 million in 2014, 2013 and 2012, respectively. The Company has accrued approximately $31 million and $30 million for the payment of interest and penalties as of January 31, 2015 and February 1, 2014, respectively. Accrued interest and penalties are included within Other Long-term Liabilities on the Consolidated Balance Sheets.

The Company files U.S. federal income tax returns as well as income tax returns in various states and in non-U.S. jurisdictions. At the end of 2014, the Company was subject to examination by the IRS for 2011 through 2013. The Company is also subject to various U.S. state and local income tax examinations for the years 2009 to 2013. Finally, the Company is subject to multiple non-U.S. tax jurisdiction examinations for the years 2004 to 2013. In some situations, the Company determines that it does not have a filing requirement in a particular tax jurisdiction. Where no return has been filed, no statute of limitations applies. Accordingly, if a tax jurisdiction reaches a conclusion that a filing requirement does exist, additional years may be reviewed by the tax authority. The Company believes it has appropriately accounted for uncertainties related to this issue.