INCOME TAXES

The components of Profit before income taxes for the years ended December 31, were as follows:



(Millions of dollars)
	2014		2013		2012
U.S.	$	207	$	91	$	31
Non-U.S.	546		603		553
Total	$	753	$	694	$	584

Profit before income taxes, as shown above, is based on the location of the entity to which such earnings are attributable. Where an entity’s earnings are subject to taxation, however, may not correlate solely to where an entity is located. For example, the profit before tax reported in the United States may be subject to tax by non-U.S. jurisdictions and profit before tax outside the United States may be subject to tax in the United States. Thus, the income tax provision shown below as U.S. or non-U.S. may not correspond to the earnings shown above.

The components of the Provision for income taxes were as follows for the years ended December 31:



(Millions of dollars)
	2014			2013			2012
Current income tax provision (benefit):
U.S.	$	14		$	(14	)	$	14
Non-U.S.	138			183			179
State (U.S.)	(1		)	—			(2		)
	151			169			191

Deferred income tax provision (benefit):
U.S.	44			17			(16		)
Non-U.S.	13			(18		)	(27		)
State (U.S.)	1			(1		)	(3		)
	58			(2		)	(46		)

Total Provision for income taxes	$	209		$	167		$	145

Current income tax provision is the amount of income taxes reported or expected to be reported on our income tax returns. We join Caterpillar in the filing of a consolidated U.S. Federal income tax return and certain state income tax returns. In accordance with our tax sharing agreement with Caterpillar, we generally pay to or receive from Caterpillar our allocated share of income taxes or credits reflected in these consolidated filings. This amount is calculated on a separate return basis by taking taxable income times the applicable statutory tax rate.

The actual Provision for income taxes differs from the Provision for income taxes that would result from applying the U.S. statutory rate to Profit before income taxes for the years ended December 31, for the reasons set forth in the following reconciliation:



(Millions of dollars)
	2014					2013					2012
Taxes computed at U.S. statutory rates	$	264		35.0	%	$	243		35.0	%	$	204		35.0	%
(Decreases) increases in taxes resulting from:
State Income Tax, net of Federal Tax	—			—	%	(1		)	(0.1	)%	(3		)	(0.5	)%
Subsidiaries' results subject to tax rates other than U.S. statutory rates	(53		)	(7.0	)%	(68		)	(9.8	)%	(50		)	(8.6	)%
Other, net	(2		)	(0.2	)%	(7		)	(1.0	)%	(6		)	(1.0	)%
Provision for income taxes	$	209		27.8	%	$	167		24.1	%	$	145		24.9	%

We have recorded income tax expense at U.S. tax rates on all profits, except for undistributed profits of non-U.S. subsidiaries of approximately $2 billion, which are considered indefinitely reinvested. Determination of the amount of unrecognized deferred income tax liability related to indefinitely reinvested profits is not feasible. If U.S. tax law changes in the future, there may be a significant negative impact on the provision for income taxes to record an incremental tax liability in the period the change occurs.

Accounting for income taxes under generally accepted accounting principles in the United States of America requires individual tax-paying entities of the Company to offset deferred income tax assets and liabilities within each particular tax jurisdiction and present them as a single amount in the Consolidated Statements of Financial Position. Amounts in different tax jurisdictions cannot be offset against each other. The amounts of deferred income taxes at December 31, included in the following lines in our Consolidated Statements of Financial Position were:



(Millions of dollars)
	2014			2013			2012
Assets:
Deferred and refundable income taxes	$	94		$	103		$	104
Liabilities:
Deferred income taxes and other liabilities	(668		)	(500		)	(535		)
Deferred income taxes, net	$	(574	)	$	(397	)	$	(431	)

Differences between accounting rules and income tax laws cause differences between the bases of certain assets and liabilities for financial reporting and income tax purposes. The income tax effects of these differences, to the extent they are temporary, are recorded as deferred income tax assets and liabilities netted by tax jurisdiction and taxpayer.

Our consolidated deferred income taxes consisted of the following components as of December 31:



(Millions of dollars)
	2014			2013			2012
Deferred tax assets:
Allowance for credit losses	$	149		$	144		$	159
Net operating loss carryforwards	46			56			59
	195			200			218

Deferred income tax liabilities (primarily lease basis differences)	(514		)	(455		)	(467		)

Valuation allowance for deferred income tax assets	(3		)	(9		)	(9		)

Deferred income tax on translation adjustment	(252		)	(133		)	(173		)

Deferred income taxes, net	$	(574	)	$	(397	)	$	(431	)

As of December 31, 2014, amounts and expiration dates of net operating loss (NOL) carryforwards in various U.S. state taxing jurisdictions were:



(Millions of dollars)
2015		2016		2017		2018		2019-2030		Total
$	—	$	—	$	—	$	6	$	130	$	136

The gross deferred income tax asset associated with these NOL carryforwards is $11 million as of December 31, 2014, partially offset by a valuation allowance of less than $1 million. The valuation allowance indicates the loss carryforwards are likely to expire prior to utilization.

In some U.S. state income tax jurisdictions, we join with other Caterpillar entities in filing combined income tax returns. In other U.S. state income tax jurisdictions, we file on a separate, stand-alone basis.

As of December 31, 2014, amounts and expiration dates of NOL carryforwards in various non-U.S. taxing jurisdictions were:



(Millions of dollars)
2015		2016		2017		2018		2019-2030		Unlimited		Total
$	3	$	1	$	—	$	—	$	14	$	139	$	157

Valuation allowances totaling $2 million have been recorded at certain non-U.S. subsidiaries that have not yet demonstrated consistent and/or sustainable profitability to support the recognition of net deferred income tax assets.

A reconciliation of the beginning and ending amounts of gross unrecognized income tax benefits for uncertain income tax positions, including positions impacting only the timing of income tax benefits was as follows:



(Millions of dollars)
	2014		2013			2012
Reconciliation of unrecognized income tax benefits⁽¹⁾:
Balance at beginning of year	$	—	$	2		$	—
Additions for income tax positions related to prior year	—		—			2
Reductions for income tax positions related to settlements⁽²⁾	—		(2		)	—
Balance at end of year	$	—	$	—		$	2

Amount that, if recognized, would impact the effective tax rate	$	—	$	—		$	2

⁽¹⁾Foreign currency translation amounts are included within each line as applicable.

⁽²⁾Includes cash payment or other reduction of assets to settle liability.

We classify interest and penalties on income taxes as a component of the Provision for income taxes. During the years ended December 31, 2014, 2013 and 2012, we recognized a benefit of less than $1 million, a benefit of less than $1 million and a benefit of $5 million in interest and penalties, respectively. As of December 31, 2014, 2013 and 2012, the total amount of accrued interest and penalties was less than $1 million.

It is reasonably possible that the amount of unrecognized income tax benefits will change in the next 12 months. On January 30, 2015, Caterpillar received a Revenue Agent's Report (RAR) from the Internal Revenue Service (IRS) indicating the end of field examination of our U.S. tax returns for 2007 to 2009. In the opinion of management, the ultimate disposition of the matters raised in this report will not have a material adverse effect on our financial position, liquidity or results of operations. We expect the IRS field examination of our U.S. tax returns for 2010 to 2012 to begin in 2015.

In our major non-U.S. jurisdictions, tax years are typically subject to examination for three to six years.