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Income Taxes
3 Months Ended
Mar. 31, 2021
Income Tax Disclosure [Abstract]  
INCOME TAXES
6. INCOME TAXES

Income tax provisions for interim (quarterly) periods are based on an estimated annual effective income tax rate calculated separately from the effect of significant, infrequent or unusual items. Income tax expense was $17 million for the three months ended March 31, 2021 compared to $1 million for the three months ended March 31, 2020. The change was primarily driven by higher income before taxes and a decrease in discrete tax benefits in the three months ended March 31, 2021. The discrete tax benefits recorded in the three months ended March 31, 2020 included $2 million related to an error in the calculation of the permanent differences on stock compensation and $3 million for the write-off of tax payables incorrectly recorded in prior periods.

The Company regularly reviews our deferred tax assets for recoverability based on the evaluation of positive and negative evidence. For the three year period ended March 31, 2021, the Company’s U.S. operations had a cumulative net loss before income taxes, as adjusted for permanent differences, which is generally considered a negative indicator of the Company’s ability to realize the benefits of its deferred tax assets. However, after weighing all evidence, including our history of U.S. pre-tax income adjusted for permanent differences, the impact of the COVID-19 pandemic on our U.S. results in 2020 and in the near-term, projected U.S. taxable income, and the length of time over which the Company’s deferred tax assets may be realized, the Company determined that realization of the related benefits was more likely than not. If the Company is unable to generate sufficient future U.S. taxable income of the proper source in the time period within which the temporary differences underlying our deferred tax assets become deductible or before the expiration of our loss and credit carryforwards, additional valuation allowances could be required in the future.

The Company engages in continuous discussions and negotiations with taxing authorities regarding tax matters, and the Company has determined that over the next 12 months it expects to resolve certain tax matters related to U.S. and foreign jurisdictions. As a result, as of March 31, 2021, we estimate that it is reasonably possible that gross unrecognized tax benefits may decrease by $10 million to $28 million in the next 12 months.