Income Taxes

12 Months Ended

Dec. 31, 2014

NOTE 4 INCOME TAXES

U.S. Cellular is included in a consolidated federal income tax return and in certain state income tax returns with other members of the TDS consolidated group. For financial statement purposes, U.S. Cellular and its subsidiaries compute their income tax expense as if they comprised a separate affiliated group and were not included in the TDS consolidated group.

U.S. Cellular's current income taxes balances at December 31, 2014 and 2013 were as follows:

December 31,	2014		2013
(Dollars in thousands)
Federal income taxes receivable (payable)	$	73,510	$	(32,351)
Net state income taxes receivable (payable)		1,199		(1,545)

Income tax expense (benefit) is summarized as follows:

Year Ended December 31,		2014		2013		2012
(Dollars in thousands)
Current
	Federal	$	(77,931)	$	180,056	$	10,547
	State		8,545		8,426		4,186
Deferred
	Federal		44,881		(69,917)		54,490
	State		6,276		(5,431)		(5,246)
	State - valuation allowance adjustment		6,447		-		-
		$	(11,782)	$	113,134	$	63,977

A reconciliation of U.S. Cellular's income tax expense computed at the statutory rate to the reported income tax expense, and the statutory federal income tax expense rate to U.S. Cellular's effective income tax expense rate is as follows:

Year Ended December 31,		2014				2013				2012
		Amount		Rate		Amount		Rate		Amount		Rate
(Dollars in millions)
Statutory federal income tax expense and rate		$	(20.5)	35.0	%	$	90.2	35.0	%	$	71.8	35.0	%
State income taxes, net of federal benefit (1)			12.2	(20.8)			5.2	2.0			3.7	1.8
Effect of noncontrolling interests			(5.8)	9.8			(2.2)	(0.9)			(6.3)	(3.1)
Gains (losses) on investments and sale of assets (2)			-	-			20.5	8.0			-	-
Correction of deferred taxes (3)			-	-			-	-			(5.3)	(2.6)
Other differences, net			2.3	(3.9)			(0.6)	(0.2)			0.1	0.1
Total income tax expense and rate		$	(11.8)	20.1	%	$	113.1	43.9	%	$	64.0	31.2	%

(1)	State income taxes, net of federal benefit, include changes in unrecognized tax benefits as well as adjustments to the valuation allowance. During the third quarter of 2014 U.S. Cellular recorded a $6.4 million increase to income tax expense related to a valuation allowance recorded against certain state deferred tax assets. In each interim period, U.S. Cellular evaluates the available positive and negative evidence to assess whether deferred tax assets are realizable, on a more likely than not basis. During the year ended December 31, 2014, based on revised forecasts of future state income, U.S. Cellular concluded that the negative evidence related to the realization of certain state deferred tax assets outweighed the positive evidence. Accordingly, U.S. Cellular determined that such deferred tax assets related to certain states were not realizable, on a more likely than not basis.

(2)	Gains (losses) on investments and sale of assets represents 2013 tax expense related to the NY1 & NY2 Deconsolidation and the Divestiture Transaction.

(3)	Correction of deferred taxes reflects immaterial adjustments to correct deferred tax balances in 2012 related to tax basis and law changes that related to periods prior to 2012.

Significant components of U.S. Cellular’s deferred income tax assets and liabilities at December 31, 2014 and 2013 were as follows:

December 31,		2014		2013
(Dollars in thousands)
Deferred tax assets
	Current deferred tax assets	$	96,886	$	102,088
	Net operating loss (“NOL”) carryforwards		72,878		61,294
	Stock-based compensation		21,072		19,028
	Compensation and benefits - other		2,586		3,746
	Deferred rent		18,513		19,462
	Other		26,116		24,604
	Total deferred tax assets		238,051		230,222
	Less valuation allowance		(53,119)		(43,375)
	Net deferred tax assets		184,932		186,847
Deferred tax liabilities
	Property, plant and equipment		520,723		503,491
	Licenses/intangibles		275,456		282,764
	Partnership investments		149,371		133,931
	Other		4,135		3,853
	Total deferred tax liabilities		949,685		924,039
Net deferred income tax liability		$	764,753	$	737,192

At December 31, 2014, U.S. Cellular and certain subsidiaries had $1,439.4 million of state NOL carryforwards (generating a $59.4 million deferred tax asset) available to offset future taxable income. The state NOL carryforwards expire between 2015 and 2034. Certain subsidiaries had federal NOL carryforwards (generating a $13.5 million deferred tax asset) available to offset their future taxable income. The federal NOL carryforwards expire between 2018 and 2034. A valuation allowance was established for certain state NOL carryforwards and federal NOL carryforwards since it is more likely than not that a portion of such carryforwards will expire before they can be utilized.

A summary of U.S. Cellular’s deferred tax asset valuation allowance is as follows:

		2014		2013		2012
(Dollars in thousands)
Balance at January 1,		$	43,375	$	41,295	$	30,261
	Charged to income tax expense		9,744		(1,527)		3,033
	Charged to other accounts		-		3,607		8,001
Balance at December 31,		$	53,119	$	43,375	$	41,295

As of December 31, 2014, the valuation allowance reduced current deferred tax assets by $3.8 million and noncurrent deferred tax assets by $49.2 million.

A reconciliation of the beginning and ending amount of unrecognized tax benefits is as follows:

		2014		2013		2012
(Dollars in thousands)
Unrecognized tax benefits balance at January 1,		$	28,813	$	26,460	$	28,745
	Additions for tax positions of current year		7,766		5,925		6,656
	Additions for tax positions of prior years		154		1,501		854
	Reductions for tax positions of prior years		(554)		(45)		(115)
	Reductions for settlements of tax positions		-		(576)		-
	Reductions for lapses in statutes of limitations		(104)		(4,452)		(9,680)
Unrecognized tax benefits balance at December 31,		$	36,075	$	28,813	$	26,460

Unrecognized tax benefits are included in Accrued taxes and Other deferred liabilities and credits in the Consolidated Balance Sheet. If these benefits were recognized, they would have reduced income tax expense in 2014, 2013 and 2012 by $23.4 million, $18.7 million and $17.2 million, respectively, net of the federal benefit from state income taxes. As of December 31, 2014, it is reasonably possible that unrecognized tax benefits could decrease by approximately $10 million in the next twelve months. The nature of the uncertainty relates primarily to state income tax positions and their resolution or the expiration of statutes of limitation.

U.S. Cellular recognizes accrued interest and penalties related to unrecognized tax benefits in Income tax expense. The amounts charged to income tax expense related to interest and penalties resulted in an expense of $3.5 million and $0.6 million in 2014 and 2013, respectively, and a benefit of $2.2 million in 2012. Net accrued interest and penalties were $16.2 million and $12.3 million at December 31, 2014 and 2013, respectively.

U.S. Cellular is included in TDS' consolidated federal income tax return. U.S. Cellular also files various state and local income tax returns. The TDS consolidated group remains subject to federal income tax audits for the tax years after 2011. With only a few exceptions, TDS is no longer subject to state income tax audits for years prior to 2010.

- Definition

The entire disclosure for income taxes. Disclosures may include net deferred tax liability or asset recognized in an enterprise's statement of financial position, net change during the year in the total valuation allowance, approximate tax effect of each type of temporary difference and carryforward that gives rise to a significant portion of deferred tax liabilities and deferred tax assets, utilization of a tax carryback, and tax uncertainties information.

+ References+ Details