Income Taxes (Tables)

12 Months Ended

Dec. 31, 2020

Income Taxes [Line Items]

Provision for (Benefit From) Income Taxes

The provision for (benefit from) income taxes consists of the following:

		Year Ended December 31,
		2020		2019		2018
Current
	Federal	$	(5)	$	(3)	$	(7)
	State	21		41		36
	Foreign	29		50		59
	Current income tax provision	45		88		88
Deferred
	Federal	(104)		41		63
	State	(90)		(37)		(39)
	Foreign	(123)		(107)		(10)
	Deferred income tax provision	(317)		(103)		14
Provision for (benefit from) income taxes		$	(272)	$	(15)	$	102

Pretax Income (Loss) for Domestic and Foreign Operations

Pretax income for domestic and foreign operations consists of the following:

	Year Ended December 31,
	2020		2019		2018
United States	$	(590)	$	125	$	114
Foreign	(366)		162		153
Pretax income (loss)	$	(956)	$	287	$	267

Deferred Income Tax Assets and Liabilities

Deferred income tax assets and liabilities are comprised of the following:

		As of December 31,
		2020		2019
Deferred income tax assets:
	Net tax loss carryforwards	$	1,146	$	1,645
	Long-term operating lease liabilities	657		678
	Accrued liabilities and deferred revenue	237		236
	Tax credits	17		20
	Depreciation and amortization	3		17
	Provision for doubtful accounts	8		8
	Other	110		75
	Valuation allowance (a)	(204)		(214)
Deferred income tax assets		1,974		2,465
Deferred income tax liabilities:
	Operating lease right-of-use assets	649		672
	Depreciation and amortization	105		108
	Prepaid expenses	8		17
	Other	14		6
Deferred income tax liabilities		776		803
Deferred income tax assets, net		$	1,198	$	1,662

__________

(a)    The valuation allowance of $204 million at December 31, 2020 relates to tax loss carryforwards and certain deferred tax assets of $195 million and $9 million, respectively. The valuation allowance will be reduced when and if the Company determines it is more likely than not that the related deferred income tax assets will be realized. The valuation allowance of $214 million at December 31, 2019 relates to tax loss carryforwards and certain deferred tax assets of $192 million and $22 million, respectively. The valuation allowance will be reduced when and if the Company determines it is more likely than not that the related deferred income tax assets will be realized.

Reconciliation of U.S Federal Income Tax Statutory Rate and Effective Income Tax Rate

The reconciliation between the U.S. federal income tax statutory rate and the Company’s effective income tax rate is as follows:

		Year Ended December 31,
		2020		2019		2018
U.S. federal statutory rate		21.0	%	21.0	%	21.0	%
Adjustments to reconcile to the effective rate:
	State and local income taxes, net of federal tax benefits	4.8		(1.7)		5.5
	Changes in valuation allowances	—		(26.9)		6.3
	Taxes on foreign operations at rates different than U.S. federal statutory rates	3.1		3.4		(5.2)
	Stock-based compensation	(0.1)		—		(0.8)
	Tax Act (benefit) expense	—		—		11.2
	Other non-deductible (non-taxable) items	(0.4)		(1.4)		1.1
	Other	—		0.4		(0.9)
		28.4	%	(5.2)	%	38.2	%

Changes in Gross Unrecognized Tax Benefits

The following is a tabular reconciliation of the gross amount of unrecognized tax benefits for the year:

		2020		2019		2018
Balance, January 1		$	54	$	61	$	63
	Additions for tax positions related to current year	4		6		8
	Reductions for tax positions for prior years	(1)		(8)		(6)
	Settlements	(3)		(4)		(3)
	Statute of limitations	—		(1)		(1)
	Foreign currency translation	3		—		—
Balance, December 31		$	57	$	54	$	61

Unrecognized Tax Benefits

The following table presents unrecognized tax benefits: 

	As of December 31,
	2020		2019
Unrecognized tax benefit in non-current income taxes payable (a)	$	24	$	57
Accrued interest payable on potential tax liabilities (b)	29		27

__________

(a)Pursuant to the agreements governing the disposition of certain subsidiaries in 2006, the Company is entitled to indemnification for certain pre-disposition tax contingencies. As of December 31, 2020 and 2019, $13 million, respectively, of unrecognized tax benefits are related to tax contingencies for which the Company believes it is entitled to indemnification.

(b)The Company recognizes potential interest related to unrecognized tax benefits within interest expense related to corporate debt, net on the accompanying Consolidated Statements of Operations. Penalties incurred during the years ended December 31, 2020, 2019 and 2018, were not significant and were recognized as a component of the provision for income taxes.

Vehicle Programs

Income Taxes [Line Items]

Deferred Income Tax Assets and Liabilities

Deferred income tax assets and liabilities related to vehicle programs are comprised of the following: 

	As of December 31,
	2020		2019
Deferred income tax assets:
Depreciation and amortization	$	62	$	54
Other	27		48
Deferred income tax assets	89		102
Deferred income tax liabilities:
Depreciation and amortization	1,445		2,243
Other	27		48
Deferred income tax liabilities	1,472		2,291
Deferred income tax liabilities under vehicle programs, net	$	1,383	$	2,189