Income Taxes

The following is a reconciliation of the federal statutory income tax rate to income tax expense in fiscal 2017, 2016 and 2015 ($ in millions):



	2017			2016			2015
Federal income tax at the statutory rate	$	635		$	458		$	485
State income taxes, net of federal benefit	38			38			43
(Benefit) expense from foreign operations	(46		)	5			(23		)
Other	(18		)	2			(11		)
Legal entity reorganization	—			—			(353		)
Income tax expense	$	609		$	503		$	141
Effective income tax rate	33.5		%	38.4		%	10.1		%

Legal Entity Reorganization

In the fourth quarter of fiscal 2012, we purchased Carphone Warehouse Group plc's interest in the Best Buy Mobile profit share agreement for $1.3 billion (the “Mobile buy-out”). The Mobile buy-out completed by our U.K. subsidiary resulted in the $1.3 billion purchase price being assigned, for U.S. tax purposes only, to an intangible asset. The Mobile buy-out did not, however, result in a similar intangible asset in the U.K., as the Mobile buy-out was considered part of a tax-free equity transaction for U.K. tax purposes.

Because the U.S. tax basis in the intangible asset was considered under U.S. tax law to be held by our U.K. subsidiary, which was regarded as a foreign corporation for U.S. tax purposes, Accounting Standards Codification ("ASC") 740, Income Taxes, requires that no deferred tax asset may be recorded in respect of the intangible asset. ASC 740-30-25-9 also precludes the recording of a deferred tax asset on the outside basis difference of the U.K. subsidiary. As a result, the amortization of the U.S. tax basis in the intangible asset only resulted in a periodic income tax benefit by reducing the amount of the U.K. subsidiary’s income, if any, that would otherwise have been subject to U.S. income taxes.

In the first quarter of fiscal 2015, we filed an election with the Internal Revenue Service to treat the U.K. subsidiary as a disregarded entity such that its assets are now deemed to be assets held directly by a U.S. entity for U.S. tax purposes. This tax-only election, which resulted in the liquidation of the U.K. subsidiary for U.S. tax purposes, resulted in the elimination of our outside basis difference in the U.K. subsidiary. Additionally, the election resulted in the recognition of a deferred tax asset (and corresponding income tax benefit) for the remaining unrecognized inside tax basis in the intangible, in a manner similar to a change in tax status as provided in ASC 740-10-25-32.

Earnings from continuing operations before income tax expense by jurisdiction was as follows in fiscal 2017, 2016 and 2015 ($ in millions):



	2017		2016		2015
United States	$	1,507	$	1,310	$	1,201
Outside the United States	309		—		186
Earnings from continuing operations before income tax expense	$	1,816	$	1,310	$	1,387

Income tax expense was comprised of the following in fiscal 2017, 2016 and 2015 ($ in millions):



	2017		2016			2015
Current:
Federal	$	317	$	347		$	354
State	37		48			51
Foreign	54		60			33
	408		455			438
Deferred:
Federal	163		65			(275		)
State	21		10			(26		)
Foreign	17		(27		)	4
	201		48			(297		)
Income tax expense	$	609	$	503		$	141

Deferred taxes are the result of differences between the bases of assets and liabilities for financial reporting and income tax purposes. Deferred tax assets and liabilities were comprised of the following ($ in millions):



	January 28, 2017			January 30, 2016
Accrued property expenses	$	91		$	175
Other accrued expenses	76			78
Deferred revenue	104			99
Compensation and benefits	43			99
Stock-based compensation	64			86
Goodwill and intangibles	210			253
Loss and credit carryforwards	123			133
Other	59			86
Total deferred tax assets	770			1,009
Valuation allowance	(94		)	(108		)
Total deferred tax assets after valuation allowance	676			901
Property and equipment	(240		)	(296		)
Inventory	(97		)	(69		)
Other	(22		)	(26		)
Total deferred tax liabilities	(359		)	(391		)
Net deferred tax assets	$	317		$	510

Net deferred tax assets are included in our Consolidated Balance Sheets as other assets as of January 28, 2017, and January 30, 2016.

At January 28, 2017, we had total net operating loss carryforwards from international operations of $77 million, of which $70 million will expire in various years through 2036 and the remaining amounts have no expiration. Additionally, we had acquired U.S. federal net operating loss carryforwards of $17 million, which expire between 2023 and 2030; U.S. federal foreign tax credit carryforwards of $1 million, which expire between 2023 and 2026; U.S. federal capital loss carryforwards of $3 million, which expire in 2022; state credit carryforwards of $10 million, which expire in 2024; state capital loss carryforwards of $5 million, which expire in 2019; international credit carryforwards of $2 million, which have no expiration; and international capital loss carryforwards of $8 million, which have no expiration.

At January 28, 2017, a valuation allowance of $94 million had been established, of which $1 million is against U.S. federal foreign tax credit carryforwards; $16 million is against international, U.S. federal and state capital loss carryforwards; $7 million is against state credit carryforwards and other state deferred tax assets; and $70 million is against certain international net operating loss carryforwards and other international deferred tax assets. The $14 million decrease from January 30, 2016, is primarily due to the exchange rate impact on the valuation allowance against certain international net operating loss carryforwards.

We have not provided deferred taxes on unremitted earnings attributable to foreign operations that have been considered to be reinvested indefinitely. These earnings relate to ongoing operations and were $1.1 billion at January 28, 2017. It is not practicable to determine the income tax liability that would be payable if such earnings were not indefinitely reinvested.

The following table provides a reconciliation of changes in unrecognized tax benefits for fiscal 2017, 2016 and 2015 ($ in millions):



	2017			2016			2015
Balance at beginning of period	$	469		$	410		$	370
Gross increases related to prior period tax positions	11			30			33
Gross decreases related to prior period tax positions	(144		)	(13		)	(88		)
Gross increases related to current period tax positions	55			59			114
Settlements with taxing authorities	(12		)	(9		)	(9		)
Lapse of statute of limitations	(5		)	(8		)	(10		)
Balance at end of period	$	374		$	469		$	410

Unrecognized tax benefits of $346 million, $337 million and $297 million at January 28, 2017, January 30, 2016, and January 31, 2015, respectively, would favorably impact our effective income tax rate if recognized.

We recognize interest and penalties (not included in the "unrecognized tax benefits" above), as well as interest received from favorable tax settlements, as components of income tax expense. Interest income of $9 million was recognized in fiscal 2017. At January 28, 2017, January 30, 2016, and January 31, 2015, we had accrued interest of $61 million, $89 million and $78 million, respectively, along with accrued penalties of $1 million, $1 million and $2 million at January 28, 2017, January 30, 2016, and January 31, 2015, respectively.

We file a consolidated U.S. federal income tax return, as well as income tax returns in various states and foreign jurisdictions. With few exceptions, we are no longer subject to U.S. federal, state and local, or non-U.S. income tax examinations by tax authorities for years before fiscal 2007.

Because existing tax positions will continue to generate increased liabilities for us for unrecognized tax benefits over the next 12 months, and since we are routinely under audit by various taxing authorities, it is reasonably possible that the amount of unrecognized tax benefits will change during the next 12 months. An estimate of the amount or range of such change cannot be made at this time. However, we do not expect the change, if any, to have a material effect on our consolidated financial condition, results of operations or cash flows within the next 12 months.