Income Taxes (Tables)

12 Months Ended

Dec. 31, 2023

Income Tax Disclosure [Abstract]

Schedule of Provision for (Benefit From) Income Taxes

The provision for income taxes consists of the following:

		Year Ended December 31,
		2023		2022		2021
Current
	Federal	$	—	$	—	$	—
	State	45		137		35
	Foreign	43		61		12
	Current income tax provision	88		198		47
Deferred
	Federal	77		622		309
	State	47		(22)		78
	Foreign	67		82		(9)
	Deferred income tax provision	191		682		378
Provision for income taxes		$	279	$	880	$	425

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

Income before income taxes is comprised of the following:

	Year Ended December 31,
	2023		2022		2021
United States (U.S.)	$	1,418	$	3,114	$	1,529
Foreign	496		522		179
Income before income taxes	$	1,914	$	3,636	$	1,708

Schedule of Deferred Income Tax Assets and Liabilities

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

		As of December 31,
		2023		2022
Deferred income tax assets:
	Net tax loss carryforwards	$	1,373	$	1,109
	Long-term operating lease liabilities	703		666
	Accrued liabilities and deferred revenue	169		231
	Tax credits	323		38
	Depreciation and amortization	22		25
	Provision for doubtful accounts	18		19
	Other	213		167
	Valuation allowance (a)	(103)		(101)
Deferred income tax assets		2,718		2,154
Deferred income tax liabilities:
	Operating lease right-of-use assets	693		657
	Depreciation and amortization	117		90
	Prepaid expenses	33		24
	Other	7		4
Deferred income tax liabilities		850		775
Deferred income tax assets, net		$	1,868	$	1,379

__________

(a)    The valuation allowance at December 31, 2023 relates to tax loss carryforwards and certain deferred tax assets of $100 million and $3 million, respectively. The valuation allowance at December 31, 2022 relates to tax loss carryforwards and certain deferred tax assets of $97 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.

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

	As of December 31,
	2023		2022
Deferred income tax assets:
Depreciation and amortization	$	80	$	63
Other	28		22
Deferred income tax assets	108		85
Deferred income tax liabilities:
Depreciation and amortization	3,497		2,815
Other	29		24
Deferred income tax liabilities	3,526		2,839
Deferred income tax liabilities under vehicle programs, net	$	3,418	$	2,754

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,
		2023		2022		2021
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	4.0		3.9		5.5
	Changes in valuation allowances	—		(1.3)		(0.6)
	Taxes on foreign operations at rates different than U.S. federal statutory rates	2.8		1.2		(2.0)
	Tax credits (a)	(11.7)		(0.4)		—
	Stock-based compensation	(1.1)		(0.5)		(0.3)
	Other non-deductible (non-taxable) items	0.7		0.4		0.6
	Other (a)	(1.1)		(0.1)		0.7
		14.6	%	24.2	%	24.9	%

_______

(a)For the year ended December 31, 2022, we reclassified (0.4%) of certain tax credits to conform to the current year presentation. This reclassification had no impact to our reported effective income tax rate.

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:

		2023		2022		2021
Balance, January 1		$	53	$	58	$	57
	Additions for tax positions related to current year	5		4		4
	Additions for tax positions for prior years	5		3		3
	Reductions for tax positions for prior years	—		(5)		(3)
	Settlements	—		(5)		—
	Statute of limitations	(2)		—		—
	Foreign currency translation	2		(2)		(3)
Balance, December 31		$	63	$	53	$	58

Schedule of Unrecognized Tax Benefits

The following table presents unrecognized tax benefits:

	As of December 31,
	2023		2022
Unrecognized tax benefits in current income taxes payable (a)	$	17	$	—
Unrecognized tax benefits in non-current income taxes payable (a)	21		33
Accrued interest payable on potential tax liabilities (b)	44		31

__________

(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, 2023, $17 million of unrecognized tax benefits in current income taxes payable are related to tax contingencies which we believe we are entitled to indemnification. As of December 31, 2022, $13 million unrecognized tax benefits in non-current income taxes payable 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, 2023, 2022 and 2021, were not significant and were recognized as a component of the provision for income taxes.