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Income Taxes
12 Months Ended
Dec. 31, 2022
Income Tax Disclosure [Abstract]  
Income Taxes Income Taxes
The components of the income tax expense are as follows:
Years Ended December 31,
202220212020
(Dollars in millions)
Federal
Current$— — — 
Deferred271 125 162 
State and local
Current21 12 22 
Deferred28 42 
Foreign
Current26 16 19 
Deferred(66)16 (24)
Total income tax expense$256 197 221 
Years Ended December 31,
202220212020
(Dollars in millions)
Income tax expense was allocated as follows:
Income tax expense in the consolidated statements of operations:
Attributable to income$256 197 221 
Member's equity:
Tax effect of the change in accumulated other comprehensive loss$(58)(30)43 

The following is a reconciliation from the statutory federal income tax rate to our effective income tax rate:

Years Ended December 31,
202220212020
(Percentage of pre-tax income)
Statutory federal income tax rate21.0 %21.0 %21.0 %
State income taxes, net of federal income tax benefit(0.3)%4.1 %5.8 %
Goodwill impairment(21.4)%— %— %
Tax law changes— %— %(1.5)%
Divestiture of business(1)
(5.1)%— %— %
Net foreign income tax0.2 %1.6 %0.9 %
Research and development credits0.1 %(0.4)%(0.6)%
Other, net(0.1)%(1.1)%(0.3)%
Effective income tax rate(5.6)%25.2 %25.3 %
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(1)Includes Global Intangible Low-Taxes Income ("GILTI") incurred as a result of the sale of our Latin American business.

For the year ended December 31, 2022, the effective tax rate is (5.6)% compared to 25.2% and 25.3% for the years ended December 31, 2021 and 2020, respectively. The effective tax rate for the year ended December 31, 2022 includes a $969 million unfavorable impact of non-deductible goodwill impairment and a $256 million unfavorable impact related to incurring GILTI as a result of the sale of our Latin American business.
The tax effects of temporary differences that gave rise to significant portions of the deferred tax assets and deferred tax liabilities were as follows:
As of December 31,
20222021
(Dollars in millions)
Deferred tax assets
Deferred revenue$261 306 
Net operating loss carry forwards1,680 3,191 
Property, plant and equipment92 71 
Other448 267 
Gross deferred tax assets2,481 3,835 
Less valuation allowance(303)(1,103)
Net deferred tax assets2,178 2,732 
Deferred tax liabilities
Deferred revenue(5)(14)
Property, plant and equipment(1,142)(1,295)
Intangible assets(1,328)(1,539)
Other(58)(20)
Gross deferred tax liabilities(2,533)(2,868)
Net deferred tax liabilities$(355)(136)

Of the $355 million and $136 million net deferred tax liabilities as of December 31, 2022 and 2021, respectively, $387 million and $212 million is reflected as a long-term liability, in other on our consolidated balance sheets and $32 million and $76 million is reflected as a net noncurrent deferred tax asset, in other, net on our consolidated balance sheets.

As of December 31, 2022, we had gross federal NOLs net of uncertain tax positions of $6.4 billion, which will expire between 2027 and 2037 if unused, and state NOLs net of uncertain tax positions of $6.1 billion.

We establish valuation allowances when necessary to reduce the deferred tax assets to amounts we expect to realize. As of December 31, 2022, a valuation allowance of $303 million was recorded as it is more likely than not that this amount of net operating loss and tax credit carryforwards will not be utilized prior to expiration. Our valuation allowance as of December 31, 2022 and 2021 is primarily related to federal capital loss carry forwards and state NOL carryforwards.

A reconciliation of the change in our gross unrecognized tax benefits (excluding both interest and any related federal benefit) from January 1 to December 31 for 2022 and 2021 is as follows:
20222021
(Dollars in millions)
Unrecognized tax benefits at beginning of period$876 923 
Tax positions of current year netted against deferred tax assets(34)— 
Tax positions of prior periods netted against deferred tax assets— (49)
Decrease in tax positions taken in the prior period(2)— 
Increase in tax positions taken in the current period
Decrease due to settlement/payments— (2)
Decrease from the lapse of statute of limitations(30)— 
Unrecognized tax benefits at end of period$813 876 
The total amount (including interest and any related federal benefit) of unrecognized tax benefits that, if recognized, would impact the effective income tax rate was $5 million and $34 million for the years ended December 31, 2022 and 2021, respectively.

Our policy is to reflect interest expense associated with unrecognized tax benefits in income tax expense. We had accrued interest (presented before related tax benefits) of approximately $1 million and $5 million as of December 31, 2022 and 2021, respectively.

We, or at least one of our affiliates, file income tax returns in the U.S. federal jurisdiction and 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 2002. The Internal Revenue Service and state and local taxing authorities reserve the right to audit any period where net operating loss carry forwards are available.

Based on our current assessment of various factors, including (i) the potential outcomes of these ongoing examinations, (ii) the expiration of statute of limitations for specific jurisdictions, (iii) the negotiated settlement of certain disputed issues, and (iv) the administrative practices of applicable taxing jurisdictions, it is reasonably possible that the related unrecognized tax benefits for uncertain tax positions previously taken may increase by up to $3 million within the next 12 months. The actual amount of such increase, if any, will depend on several future developments and events, many of which are outside our control.