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Income Taxes
 12 Months Ended
Dec. 31, 2022
Income Tax Disclosure [Abstract]  
Income Taxes
The provision for (benefit from) income taxes consists of the following:
Year Ended December 31,
202220212020
Current
Federal$— $— $(5)
State137 35 21 
Foreign61 12 29 
Current income tax provision198 47 45 
Deferred
Federal622 309 (104)
State(22)78 (90)
Foreign82 (9)(123)
Deferred income tax provision (benefit)682 378 (317)
Provision for (benefit from) income taxes$880 $425 $(272)
Income (loss) before income taxes is comprised of the following:
Year Ended December 31,
202220212020
United States$3,114 $1,529 $(590)
Foreign522 179 (366)
Income (loss) before income taxes
$3,636 $1,708 $(956)

Deferred income tax assets, net is comprised of the following:
As of December 31,
20222021
Deferred income tax assets:
Net tax loss carryforwards $1,109 $1,480 
Long-term operating lease liabilities666 625 
Accrued liabilities and deferred revenue231 272 
Tax credits38 11 
Depreciation and amortization25 19 
Provision for doubtful accounts19 18 
Other167 100 
Valuation allowance (a)
(101)(167)
Deferred income tax assets2,154 2,358 
Deferred income tax liabilities:
Operating lease right-of-use assets657 614 
Depreciation and amortization90 102 
Prepaid expenses24 23 
Other4 4 
Deferred income tax liabilities775 743 
Deferred income tax assets, net$1,379 $1,615 
__________
(a)    The valuation allowance of $101 million at December 31, 2022 relates to tax loss carryforwards and certain deferred tax assets of $97 million and $4 million, respectively. 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 allowances 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, 2021 is primarily related to a release of valuation allowance for certain state net operating losses.

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

As of December 31,
20222021
Deferred income tax assets:
Depreciation and amortization$63 $80 
Other22 19 
Deferred income tax assets85 99 
Deferred income tax liabilities:
Depreciation and amortization2,815 2,321 
Other24 20 
Deferred income tax liabilities2,839 2,341 
Deferred income tax liabilities under vehicle programs, net$2,754 $2,242 
At December 31, 2022, we had U.S. federal net operating loss carryforwards of approximately $3.6 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, 2022, we had foreign net operating loss carryforwards of approximately $1.1 billion, the majority of which has an indefinite utilization period.
At December 31, 2022, we had undistributed earnings of certain foreign subsidiaries of approximately $1.2 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,
202220212020
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 benefits3.9 5.5 4.8 
Changes in valuation allowances (1.3)(0.6)— 
Taxes on foreign operations at rates different than U.S. federal statutory rates1.2 (2.0)3.1 
Stock-based compensation(0.5)(0.3)(0.1)
Other non-deductible (non-taxable) items0.4 0.6 (0.4)
Other(0.5)0.7 — 
24.2 %24.9 %28.4 %
The following is a tabular reconciliation of the gross amount of unrecognized tax benefits for the year:
202220212020
Balance, January 1$58 $57 $54 
Additions for tax positions related to current year4 4 4 
Additions for tax positions for prior years3 3 — 
Reductions for tax positions for prior years(5)(3)(1)
Settlements(5)— (3)
Foreign currency translation(2)(3)3 
Balance, December 31$53 $58 $57 
We do not anticipate that total unrecognized tax benefits will change significantly in 2023.
We are subject to taxation in the United States and various foreign jurisdictions. As of December 31, 2022, the 2007 through 2021 tax years generally remain subject to examination by the federal tax authorities. The 2012 through 2021 tax years generally remain subject to examination by various state tax authorities. In significant foreign jurisdictions, the 2012 through 2021 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, 2022, 2021 and 2020, if recognized, would affect our provision for (benefit from) income taxes. As of December 31, 2022, our unrecognized tax benefits were offset by tax loss carryforwards and other deferred tax assets in the amount of $24 million.
The following table presents unrecognized tax benefits:
As of December 31,
20222021
Unrecognized tax benefit in non-current income taxes payable (a)
$33 $30 
Accrued interest payable on potential tax liabilities (b)
31 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, 2022 and 2021, $13 million, in each period, of unrecognized tax benefits are related to tax contingencies for which we believe we are 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, 2022, 2021 and 2020, were not significant and were recognized as a component of the provision for (benefit from) income taxes.