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Income Taxes
 12 Months Ended
Dec. 31, 2024
Income Tax Disclosure [Abstract]  
Income Taxes Income Taxes
The provision for (benefit from) income taxes consists of the following:
Year Ended December 31,
202420232022
Current
Federal$14 $— $— 
State11 45 137 
Foreign70 43 61 
Current income tax provision95 88 198 
Deferred
Federal(644)77 622 
State(211)47 (22)
Foreign(50)67 82 
Deferred income tax provision(905)191 682 
Provision for (benefit from) income taxes$(810)$279 $880 
Income (loss) before income taxes is comprised of the following:
Year Ended December 31,
202420232022
United States (U.S.)$(2,642)$1,418 $3,114 
Foreign15 496 522 
Income (loss) before income taxes
$(2,627)$1,914 $3,636 
Deferred income tax assets, net is comprised of the following:
As of December 31,
20242023
Deferred income tax assets:
Net tax loss carryforwards $983 $1,373 
Long-term operating lease liabilities807 703 
Tax credits405 323 
Deferred interest expense (a)
358 179 
Accrued liabilities and deferred revenue157 169 
Depreciation and amortization24 22 
Provision for doubtful accounts19 18 
Other (a)
28 34 
Valuation allowance (b)
(83)(103)
Deferred income tax assets2,698 2,718 
Deferred income tax liabilities:
Operating lease right of use assets793 693 
Depreciation and amortization74 117 
Prepaid expenses32 33 
Other13 7 
Deferred income tax liabilities912 850 
Deferred income tax assets, net$1,786 $1,868 
__________
(a)    For the year ended December 31, 2023, we reclassified $179 million of deferred interest expense to conform to the current year presentation. This reclassification had no impact to our reported deferred income tax assets.
(b)     The valuation allowance at December 31, 2024 relates to tax loss carryforwards and certain deferred tax assets of $80 million and $3 million, respectively. 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 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,
20242023
Deferred income tax assets:
Depreciation and amortization$73 $80 
Other20 28 
Deferred income tax assets93 108 
Deferred income tax liabilities:
Depreciation and amortization2,513 3,497 
Other22 29 
Deferred income tax liabilities2,535 3,526 
Deferred income tax liabilities under vehicle programs, net$2,442 $3,418 
At December 31, 2024, we had U.S. federal net operating loss carryforwards of approximately $3.0 billion. The net operating loss carryforwards have an indefinite utilization period pursuant to the Tax Act. 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,
2024, we had foreign net operating loss carryforwards of approximately $890 million, the majority of which has an indefinite utilization period.
At December 31, 2024, we had undistributed earnings of certain foreign subsidiaries of approximately $1.6 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,
202420232022
U.S. federal statutory rate21.0 %21.0 %21.0 %
Adjustments to reconcile to our effective rate:
State and local income taxes, net of federal tax benefits6.0 4.0 3.9 
Changes in valuation allowances 0.2 — (1.3)
Taxes on foreign operations at rates different than U.S. federal statutory rates(0.9)2.8 1.2 
Tax credits (a)
3.6 (11.7)(0.4)
Stock-based compensation0.1 (1.1)(0.5)
Other non-deductible (non-taxable) items(0.2)0.7 0.4 
Other (a)
1.0 (1.1)(0.1)
30.8 %14.6 %24.2 %
_______
(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.
The Organisation for Economic Cooperation and Development (“OECD”) published a proposal for the establishment of a global minimum tax rate of 15% (the “Pillar Two rule”), effective for fiscal 2024. We are closely monitoring developments of the Pillar Two rule as the OECD continues to refine its technical guidance and member states implement tax laws and regulations based on Pillar Two proposals. Pillar Two did not have a material impact on our Consolidated Financial Statements for 2024.

The following is a reconciliation of the gross amount of unrecognized tax benefits:
202420232022
Balance, January 1$63 $53 $58 
Additions for tax positions related to current year4 5 4 
Additions for tax positions related to prior years— 5 3 
Reductions for tax positions related to prior years(2)— (5)
Settlements— — (5)
Statute of limitations(4)(2)— 
Foreign currency translation(3)2 (2)
Balance, December 31$58 $63 $53 
We do not anticipate the gross amount of unrecognized tax benefits to change significantly in 2025.
We are subject to taxation in the U.S. and various foreign jurisdictions. As of December 31, 2024, the 2007 through 2023 tax years generally remain subject to examination by the federal tax authorities. The 2012 through 2023 tax years generally remain subject to examination by various state tax authorities. In significant foreign jurisdictions, the 2012 through 2023 tax years generally remain subject to examination by their respective tax authorities.
Substantially all of the gross amount of unrecognized tax benefits at December 31, 2024, 2023 and 2022, if recognized, would affect our provision for (benefit from) income taxes. As of December 31, 2024, our unrecognized tax benefits were offset by tax loss carryforwards and other deferred tax assets in the amount of $27 million.
The following table presents unrecognized tax benefits:
As of December 31,
20242023
Unrecognized tax benefits in current income taxes payable (a)
$17 $17 
Unrecognized tax benefits in non-current income taxes payable (a)
17 21 
Accrued interest payable on potential tax liabilities (b)
47 44 
__________
(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, 2024 and 2023, liabilities for unrecognized tax benefits associated with these tax contingencies are included in current income taxes payable.
(b)We recognize potential interest expense 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, 2024, 2023 and 2022, were not significant and were recognized in the provision for (benefit from) income taxes.