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Income Taxes
 12 Months Ended
Dec. 31, 2021
Income Tax Disclosure [Abstract]  
Income Taxes Income Taxes
The provision for (benefit from) income taxes consists of the following:
Year Ended December 31,
202120202019
Current
Federal$— $(5)$(3)
State35 21 41 
Foreign12 29 50 
Current income tax provision47 45 88 
Deferred
Federal309 (104)41 
State78 (90)(37)
Foreign(9)(123)(107)
Deferred income tax provision (benefit)378 (317)(103)
Provision for (benefit from) income taxes$425 $(272)$(15)
Pretax income (loss) for domestic and foreign operations consists of the following:
Year Ended December 31,
202120202019
United States$1,529 $(590)$125 
Foreign179 (366)162 
Pretax income (loss)$1,708 $(956)$287 
Deferred income tax assets and liabilities are comprised of the following:
As of December 31,
20212020
Deferred income tax assets:
Net tax loss carryforwards $1,480 $1,146 
Long-term operating lease liabilities625 657 
Accrued liabilities and deferred revenue272 237 
Tax credits11 17 
Depreciation and amortization19 3 
Provision for doubtful accounts18 8 
Other100 110 
Valuation allowance (a)
(167)(204)
Deferred income tax assets2,358 1,974 
Deferred income tax liabilities:
Operating lease right-of-use assets614 649 
Depreciation and amortization102 105 
Prepaid expenses23 8 
Other4 14 
Deferred income tax liabilities743 776 
Deferred income tax assets, net$1,615 $1,198 
__________
(a)    The valuation allowance of $167 million at December 31, 2021 relates to tax loss carryforwards and certain deferred tax assets of $163 million and $4 million, respectively. The valuation allowance will be reduced when and if we determine it is more likely than not that the related deferred income tax assets will be realized. 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 we determine it is more likely than not that the related deferred income tax assets will be realized. The decrease in valuation allowance as compared to the year ended December 31, 2020 relates to the expiration of certain federal net operating loss carryforwards for which the deferred income tax asset was not more likely than not to be realized. As of December 31, 2021, the net operating loss deferred tax asset and corresponding valuation allowance were reduced.

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

As of December 31,
20212020
Deferred income tax assets:
Depreciation and amortization$80 $62 
Other19 27 
Deferred income tax assets99 89 
Deferred income tax liabilities:
Depreciation and amortization2,321 1,445 
Other20 27 
Deferred income tax liabilities2,341 1,472 
Deferred income tax liabilities under vehicle programs, net$2,242 $1,383 
At December 31, 2021, we had U.S. federal net operating loss carryforwards of approximately $5.1 billion. The majority of the net operating loss carryforwards have an indefinite utilization period pursuant to the Tax Act and a significant remaining portion expires by 2031. Such net operating loss carryforwards are primarily related to accelerated depreciation of our U.S. vehicles. Currently, we do not record valuation allowances on
the majority of our U.S. federal tax loss carryforwards as there are adequate deferred tax liabilities that could be realized within the carryforward period. At December 31, 2021, we had foreign net operating loss carryforwards of approximately $1.2 billion, the majority of which has an indefinite utilization period.
At December 31, 2021, we had undistributed earnings of certain foreign subsidiaries of approximately $1.0 billion that we have indefinitely reinvested, and on which we have not recognized deferred taxes. Estimating the amount of potential tax is not practicable because of the complexity and variety of assumptions necessary to compute the tax.
The reconciliation between the U.S. federal income tax statutory rate and our effective income tax rate is as follows:
Year Ended December 31,
202120202019
U.S. federal statutory rate21.0 %21.0 %21.0 %
Adjustments to reconcile to the effective rate:
State and local income taxes, net of federal tax benefits5.5 4.8 (1.7)
Changes in valuation allowances (0.6)— (26.9)
Taxes on foreign operations at rates different than U.S. federal statutory rates(2.0)3.1 3.4 
Stock-based compensation(0.3)(0.1)— 
Other non-deductible (non-taxable) items0.6 (0.4)(1.4)
Other0.7 — 0.4 
24.9 %28.4 %(5.2)%

The following is a tabular reconciliation of the gross amount of unrecognized tax benefits for the year:
202120202019
Balance, January 1$57 $54 $61 
Additions for tax positions related to current year4 4 6 
Additions for tax positions for prior years3 — — 
Reductions for tax positions for prior years(3)(1)(8)
Settlements— (3)(4)
Statute of limitations— — (1)
Foreign currency translation(3)3 — 
Balance, December 31$58 $57 $54 
We do not anticipate that total unrecognized tax benefits will change significantly in 2022.
We are subject to taxation in the United States and various foreign jurisdictions. As of December 31, 2021, the 2007 through 2020 tax years generally remain subject to examination by the federal tax authorities. The 2012 through 2020 tax years generally remain subject to examination by various state tax authorities. In significant foreign jurisdictions, the 2012 through 2020 tax years generally remain subject to examination by their respective tax authorities.
Substantially all of the gross amount of the unrecognized tax benefits at December 31, 2021, 2020 and 2019, if recognized, would affect our provision for, or benefit from, income taxes. As of December 31, 2021, our unrecognized tax benefits were offset by tax loss carryforwards and other deferred tax assets in the amount of $33 million.
The following table presents unrecognized tax benefits:
As of December 31,
20212020
Unrecognized tax benefit in non-current income taxes payable (a)
$30 $24 
Accrued interest payable on potential tax liabilities (b)
29 29 
__________
(a)Pursuant to the agreements governing the disposition of certain subsidiaries in 2006, we are entitled to indemnification for certain predisposition tax contingencies. As of December 31, 2021 and 2020, $13 million, respectively, of unrecognized tax benefits are related to tax contingencies for which we believe it is entitled to indemnification.
(b)We recognize 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, 2021, 2020 and 2019, were not significant and were recognized as a component of the provision for income taxes.