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Income Taxes
 12 Months Ended
Dec. 31, 2022
Income Tax Disclosure [Abstract]  
Income Taxes Income Taxes
Income (loss) from continuing operations before taxes consisted of the following:
Years Ended December 31,
202220212020
U.S.$(39,294)$(85,258)$(243,760)
International79,174 77,843 60,391 
Total$39,880 $(7,415)$(183,369)

The provision (benefit) for income taxes from continuing operations consisted of the following:
Years Ended December 31,
202220212020
U.S. Federal:
Current$223 $(7,419)$(10,582)
Deferred(12,284)(13,825)6,516 
(12,061)(21,244)(4,066)
U.S. State and Local:
Current(9,716)5,401 (2,569)
Deferred7,137 (5,827)4,100 
(2,579)(426)1,531 
International:
Current8,745 10,979 4,993 
Deferred8,835 (231)4,664 
17,580 10,748 9,657 
Total current(748)8,961 (8,158)
Total deferred3,688 (19,883)15,280 
Total provision (benefit) for income taxes$2,940 $(10,922)$7,122 
Effective tax rate7.4 %147.3 %(3.9)%
The effective tax rate for 2022 includes a tax benefit of $5 million on the pre-tax gain of $5 million from the Borderfree sale as the tax basis was higher than book basis and a $1 million benefit associated with the 2019 sale of a business.

The effective tax rate for 2021 includes benefits of $7 million from the resolution of tax matters, $5 million due to tax legislation in the U.K., $3 million from an affiliate reorganization and $2 million from the vesting of restricted stock, partially offset by charges of $6 million on the pre-tax gain of $10 million from the sale of a business as the tax basis was lower than the book basis and $1 million for the write-off of deferred tax assets associated with the expiration of out-of-the-money stock options.

The effective tax rate for 2020 includes a $12 million charge for the surrender of company owned life insurance policies, a $5 million benefit for the correction of tax balances in certain domestic and international tax jurisdictions, a $3 million benefit due to regulations enacted into law, a $2 million benefit for the carryback of net operating losses resulting from the CARES Act and a benefit of $2 million on the $198 million goodwill impairment charge as the majority of this charge is nondeductible.
A reconciliation of income taxes computed at the federal statutory rate and our provision for income taxes consist of the following:
Years Ended December 31,
202220212020
Federal statutory provision$8,375 $(1,558)$(38,507)
State and local income taxes (1)
(1,612)(336)1,209 
Impact of foreign operations taxed at rates other than the U.S. statutory rate (2)
3,349 (2,220)(3,345)
Accrual/release of uncertain tax amounts related to foreign operations(2,753)(7,288)1,802 
U.S. tax impacts of foreign income in the U.S. (3)
1,089 4,441 (2,300)
CARES Act carryback benefit— (2,270)(1,646)
Tax credits(850)(500)(750)
Unrealized stock compensation benefits572 (505)2,312 
Surrender of company-owned life insurance policies— — 10,313 
Goodwill impairment— — 40,328 
Borderfree tax basis differences(5,610)— — 
Other, net (4)
380 (686)(2,294)
Provision (benefit) for income taxes$2,940 $(10,922)$7,122 
(1)    Includes a benefit of $1 million related to tax resolutions and a benefit of $1 million for tax return true-ups for the year ended December 31, 2022 and a charge of $2 million for the surrender of company-owned life insurance for the year ended December 31, 2020.
(2)    Includes a charge of $2 million for a deferred rate change and a charge of $1 million for the establishment of a valuation allowance for the year ended December 31, 2022, a benefit of $5 million for a deferred rate change for the year ended December 31, 2021, and a benefit of $3 million for tax balance corrections and a deferred tax rate change benefit of $2 million for the year ended December 31, 2020.
(3)    Includes a benefit of $1 million associated with the sale of a 2019 business for the year ended December 31, 2022.
(4)     Includes a $3 million benefit from an affiliate reorganization and charge of $3 million related to the sale of a business for the year ended December 31, 2021, and a $2 million benefit related to tax balance corrections and a $1 million charge related to interest for the year ended December 31, 2020.
Deferred tax liabilities and assets consisted of the following:
December 31,
20222021
Deferred tax liabilities:
Depreciation$(51,717)$(85,544)
Deferred profit (for tax purposes) on sale to finance subsidiary(26,765)(26,745)
Lease revenue and related depreciation(216,282)(202,862)
Intangible assets(65,916)(76,672)
Operating lease liability(73,403)(46,496)
Other(27,366)(25,438)
Gross deferred tax liabilities(461,449)(463,757)
Deferred tax assets:
Postretirement medical benefits24,892 34,681 
Pension9,640 20,472 
Operating lease asset78,765 52,271 
Long-term incentives12,946 12,308 
Net operating and capital losses130,640 125,699 
Tax credit carry forwards66,256 65,931 
Section 163j carryforward23,917 10,556 
Tax uncertainties gross-up4,982 6,929 
Other50,345 38,641 
Gross deferred tax assets402,383 367,488 
Less: Valuation allowance(157,450)(121,778)
Net deferred tax assets244,933 245,710 
Total deferred taxes, net$(216,516)$(218,047)
The valuation allowance relates primarily to certain foreign, state and local net operating loss and tax credit carryforwards that will more-likely-than-not expire unutilized.
We have a federal net operating loss carryforward of $48 million as of December 31, 2022, the majority of which has an indefinite carryforward period. We have net operating loss carryforwards in international jurisdictions of $153 million as of December 31, 2022, of which $139 million can be carried forward indefinitely and the remainder expire over the next 20 years. We also have net operating loss carryforwards in most states totaling $932 million that will expire over the next 20 years. In addition, we have tax credit carryforwards of $66 million, of which $51 million can be carried forward indefinitely and the remainder expire over the next 10 years.

As of December 31, 2022, we assert that we are permanently reinvested in our pre-1987 and post-2017 undistributed earnings of $307 million as well as all other outside basis differences. While a determination of the full liability that would be incurred if these earnings were repatriated is not practicable, we have estimated the withholding taxes would be approximately $3 million.
Uncertain Tax Positions
A reconciliation of the amount of unrecognized tax benefits is as follows:
202220212020
Balance at beginning of year$45,072 $50,064 $60,302 
Increases from prior period positions6 3,016 2,147 
Decreases from prior period positions(6,830)(4,247)(47)
Increases from current period positions340 492 3,472 
Decreases relating to settlements with tax authorities(1,966)(1,270)(12,508)
Reductions from lapse of applicable statute of limitations(3,322)(2,983)(3,302)
Balance at end of year$33,300 $45,072 $50,064 
The amount of the unrecognized tax benefits at December 31, 2022, 2021 and 2020 that would affect the effective tax rate if recognized was $29 million, $39 million and $44 million, respectively.
On a regular basis, we conclude tax return examinations, statutes of limitations expire, and court decisions interpret tax law. We regularly assess tax uncertainties in light of these developments. As a result, it is reasonably possible that the amount of our unrecognized tax benefits will decrease in the next 12 months, and we expect this change could be up to 20% of our unrecognized tax benefits. We recognize interest and penalties related to uncertain tax positions in our provision for income taxes. Amounts included in our provision for income taxes related to interest and penalties on uncertain tax positions for each of the years ended December 31, 2022, 2021 and 2020 were not significant. We had approximately $3 million and $4 million accrued for the payment of interest and penalties at December 31, 2022 and 2021, respectively.

Other Tax Matters
With regard to U.S. Federal income tax, the Internal Revenue Service examination of our consolidated U.S. income tax returns for tax years prior to 2019 are closed to audit, except for review of the Tax Cuts and Jobs Act (TCJA) Sec 965 transition tax. On a state and local level, returns for most jurisdictions are closed through 2017. For our significant non-U.S. jurisdictions, Canada is closed to examination through 2017 except for a specific issue under current exam, and France, Germany and the U.K. are closed through 2019, 2016, and 2020 respectively. We also have other less significant tax filings currently subject to examination.
We regularly assess the likelihood of tax adjustments in each of the tax jurisdictions in which we have operations and account for the related financial statement implications. We believe we have established tax reserves that are appropriate given the possibility of tax adjustments. However, determining the appropriate level of tax reserves requires judgment regarding the uncertain application of tax law and the possibility of tax adjustments. Future changes in tax reserve requirements could have a material positive or negative impact on our results of operations, financial position and cash flows.