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Income Taxes
 12 Months Ended
Dec. 31, 2024
Income Tax Disclosure [Abstract]  
Income Taxes Income Taxes
(Loss) income from continuing operations before taxes consisted of the following:
Years Ended December 31,
202420232022
U.S.$(112,261)$(112,437)$107,186 
International59,934 68,517 81,466 
Total$(52,327)$(43,920)$188,652 

The (benefit) provision for income taxes from continuing operations consisted of the following:
Years Ended December 31,
202420232022
U.S. Federal:
Current$2,535 $32,784 $28,565 
Deferred(138,444)(31,591)(9,995)
(135,909)1,193 18,570 
U.S. State and Local:
Current1,375 9,083 (834)
Deferred(41,416)(9,973)7,036 
(40,041)(890)6,202 
International:
Current14,971 11,266 9,276 
Deferred6,150 5,778 8,908 
21,121 17,044 18,184 
Total current18,881 53,133 37,007 
Total deferred(173,710)(35,786)5,949 
Total (benefit) provision for income taxes
$(154,829)$17,347 $42,956 
Effective tax rate295.9 %(39.5)%22.8 %
The benefit for income taxes for 2024 includes a tax benefit of $164 million primarily due to an affiliate reorganization as well as a $6 million benefit related to a state interest valuation allowance release.
The effective tax rate for 2023 includes a benefit of $2 million on the aggregate $124 million goodwill impairment charge as the majority of this charge is nondeductible.
The effective tax rate for 2022 includes a tax benefit of $5 million on the pre-tax gain of $5 million from the Borderfree sale as the tax basis was higher than book basis.
A reconciliation of income taxes computed at the federal statutory rate and our provision for income taxes consist of the following:
Years Ended December 31,
202420232022
Federal statutory provision$(10,989)$(9,223)$39,617 
State and local income taxes (1)
(31,632)(703)5,325 
Impact of foreign operations taxed at rates other than the U.S. statutory rate (2)
4,595 2,779 3,472 
Accrual/release of uncertain tax amounts related to foreign operations(829)(2,829)(2,753)
U.S. tax impacts of foreign income in the U.S. (3)
7,983 1,099 1,089 
Tax credits— (69)— 
Unrealized stock compensation benefits1,686 574 572 
Surrender of company-owned life insurance policies
8,139 — — 
Nondeductible officer's compensation
5,992 — — 
Valuation allowance on capital loss carryforward
2,100 
Goodwill impairment— 24,437 — 
Affiliate reorganization
(141,723)— — 
Tax basis differences
— — (5,610)
Other, net
(151)1,282 1,244 
(Benefit) provision for income taxes
$(154,829)$17,347 $42,956 
(1)    Includes a benefit of $22 million related to the affiliate reorganization and a benefit of $6 million related to a state interest valuation allowance release for the year ended December 31, 2024 as well as $1 million related to tax resolutions and a benefit of $1 million for tax return true-ups for the year ended December 31, 2022.
(2)    Includes a charge of $1 million for a change in tax rates for the year ended December 31, 2024 and 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.
(3)    Includes a charge of $2 million for the loss of the GILTI deduction as well as a charge of $2 million for withholding tax for the year ended December 31, 2024 and a benefit of $1 million for the year ended December 31, 2022 associated with the sale of a business.
Deferred tax liabilities and assets consisted of the following:
December 31,
20242023
Deferred tax liabilities:
Depreciation$— $2,031 
Deferred profit (for tax purposes) on sale to finance subsidiary(53,370)(43,057)
Lease revenue and related depreciation(183,237)(205,773)
Intangible assets(52,773)(52,609)
Operating lease liability(27,857)(31,114)
Basis adjustment in subsidiary
— (51,548)
Other(10,847)(13,805)
Gross deferred tax liabilities(328,084)(395,875)
Deferred tax assets:
Depreciation
32,539 — 
Postretirement medical benefits20,108 23,472 
Pension16,948 15,042 
Operating lease asset31,429 35,731 
Long-term incentives5,914 11,814 
Net operating and capital losses257,186 179,153 
Tax credit carry forwards65,697 65,095 
Section 163j carryforward86,075 47,802 
Tax uncertainties gross-up4,568 4,904 
Other57,915 47,736 
Gross deferred tax assets545,840 430,749 
Less: Valuation allowance(206,441)(159,342)
Net deferred tax assets371,938 271,407 
Total deferred taxes, net$43,854 $(124,468)
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 without being utilized.
We have a federal net operating loss carryforward of $301 million as of December 31, 2024, that has an unlimited carryforward period. We have net operating loss carryforwards in international jurisdictions of $394 million as of December 31, 2024, of which $123 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 $1 billion 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, 2024, we assert that we are permanently reinvested in our pre-1987 and post-2017 undistributed earnings of $564 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 $2 million.
Uncertain Tax Positions
A reconciliation of the amount of unrecognized tax benefits is as follows:
202420232022
Balance at beginning of year$30,232 $33,300 $45,072 
Increases from prior period positions— 343 6 
Decreases from prior period positions(955)(524)(6,830)
Increases from current period positions73 400 340 
Decreases relating to settlements with tax authorities(1,467)(350)(1,966)
Reductions from lapse of applicable statute of limitations(846)(2,937)(3,322)
Balance at end of year$27,037 $30,232 $33,300 
The amount of the unrecognized tax benefits at December 31, 2024, 2023 and 2022 that would affect the effective tax rate if recognized was $24 million, $26 million and $29 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 40% 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, 2024, 2023 and 2022 were not significant. We had approximately $4 million accrued for the payment of interest and penalties at both December 31, 2024 and 2023.

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 2020 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 2019. For our significant non-U.S. jurisdictions, Canada is closed to examination through 2019 except for a specific issue under current exam, and France, Germany and the U.K. are closed through 2019, 2017, and 2022 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.