Income Taxes (Tables)

12 Months Ended

Dec. 31, 2024

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,
	2024		2023		2022
Current
Federal	$	14	$	—	$	—
State	11		45		137
Foreign	70		43		61
Current income tax provision	95		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

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

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

	Year Ended December 31,
	2024		2023		2022
United States (U.S.)	$	(2,642)	$	1,418	$	3,114
Foreign	15		496		522
Income (loss) before income taxes	$	(2,627)	$	1,914	$	3,636

Schedule of Deferred Income Tax Assets and Liabilities

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

	As of December 31,
	2024		2023
Deferred income tax assets:
Net tax loss carryforwards	$	983	$	1,373
Long-term operating lease liabilities	807		703
Tax credits	405		323
Deferred interest expense (a)	358		179
Accrued liabilities and deferred revenue	157		169
Depreciation and amortization	24		22
Provision for doubtful accounts	19		18
Other (a)	28		34
Valuation allowance (b)	(83)		(103)
Deferred income tax assets	2,698		2,718
Deferred income tax liabilities:
Operating lease right of use assets	793		693
Depreciation and amortization	74		117
Prepaid expenses	32		33
Other	13		7
Deferred income tax liabilities	912		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,
	2024		2023
Deferred income tax assets:
Depreciation and amortization	$	73	$	80
Other	20		28
Deferred income tax assets	93		108
Deferred income tax liabilities:
Depreciation and amortization	2,513		3,497
Other	22		29
Deferred income tax liabilities	2,535		3,526
Deferred income tax liabilities under vehicle programs, net	$	2,442	$	3,418

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,
	2024		2023		2022
U.S. federal statutory rate	21.0	%	21.0	%	21.0	%
Adjustments to reconcile to our effective rate:
State and local income taxes, net of federal tax benefits	6.0		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 compensation	0.1		(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.

Schedule of Unrecognized Tax Benefits Roll Forward

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

	2024		2023		2022
Balance, January 1	$	63	$	53	$	58
Additions for tax positions related to current year	4		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

Schedule of Unrecognized Tax Benefits

The following table presents unrecognized tax benefits:

	As of December 31,
	2024		2023
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.