Income Taxes (Tables)

12 Months Ended

Dec. 31, 2022

Income Tax Disclosure [Abstract]

Schedule of Provision for (Benefit From) Income Taxes

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

		Year Ended December 31,
		2022		2021		2020
Current
	Federal	$	—	$	—	$	(5)
	State	137		35		21
	Foreign	61		12		29
	Current income tax provision	198		47		45
Deferred
	Federal	622		309		(104)
	State	(22)		78		(90)
	Foreign	82		(9)		(123)
	Deferred income tax provision (benefit)	682		378		(317)
Provision for (benefit from) income taxes		$	880	$	425	$	(272)

Schedule of Pretax Income (Loss) for Domestic and Foreign Operations

Income (loss) before income taxes is comprised of the following:

	Year Ended December 31,
	2022		2021		2020
United States	$	3,114	$	1,529	$	(590)
Foreign	522		179		(366)
Income (loss) before income taxes	$	3,636	$	1,708	$	(956)

Schedule of Deferred Income Tax Assets and Liabilities

Deferred income tax assets, net is comprised of the following:

		As of December 31,
		2022		2021
Deferred income tax assets:
	Net tax loss carryforwards	$	1,109	$	1,480
	Long-term operating lease liabilities	666		625
	Accrued liabilities and deferred revenue	231		272
	Tax credits	38		11
	Depreciation and amortization	25		19
	Provision for doubtful accounts	19		18
	Other	167		100
	Valuation allowance (a)	(101)		(167)
Deferred income tax assets		2,154		2,358
Deferred income tax liabilities:
	Operating lease right-of-use assets	657		614
	Depreciation and amortization	90		102
	Prepaid expenses	24		23
	Other	4		4
Deferred income tax liabilities		775		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,
	2022		2021
Deferred income tax assets:
Depreciation and amortization	$	63	$	80
Other	22		19
Deferred income tax assets	85		99
Deferred income tax liabilities:
Depreciation and amortization	2,815		2,321
Other	24		20
Deferred income tax liabilities	2,839		2,341
Deferred income tax liabilities under vehicle programs, net	$	2,754	$	2,242

Schedule of 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 our effective income tax rate is as follows:

		Year Ended December 31,
		2022		2021		2020
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	3.9		5.5		4.8
	Changes in valuation allowances	(1.3)		(0.6)		—
	Taxes on foreign operations at rates different than U.S. federal statutory rates	1.2		(2.0)		3.1
	Stock-based compensation	(0.5)		(0.3)		(0.1)
	Other non-deductible (non-taxable) items	0.4		0.6		(0.4)
	Other	(0.5)		0.7		—
		24.2	%	24.9	%	28.4	%

Schedule of Changes in Gross Unrecognized Tax Benefits

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

		2022		2021		2020
Balance, January 1		$	58	$	57	$	54
	Additions for tax positions related to current year	4		4		4
	Additions for tax positions for prior years	3		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

Schedule of Unrecognized Tax Benefits

The following table presents unrecognized tax benefits:

	As of December 31,
	2022		2021
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.