
16.	Income Taxes

The following table provides details of income taxes (in millions, except percentages):



	Three Months Ended						Six Months Ended
	January 24, 2015			January 25, 2014			January 24, 2015			January 25, 2014
Income before provision for income taxes	$	2,873		$	1,755		$	5,233		$	4,295
Provision for income taxes	$	476		$	326		$	1,008		$	870
Effective tax rate	16.6		%	18.6		%	19.3		%	20.3		%

During the three months ended January 24, 2015, the Tax Increase Prevention Act of 2014 reinstated the U.S. federal R&D tax credit for calendar year 2014 R&D expenses. As a result, the effective tax rate for the three and six months ended January 24, 2015 reflected tax benefits related to fiscal 2015 R&D expenses and a tax benefit of $91 million related to fiscal 2014 R&D expenses.

As of January 24, 2015, the Company had $2.0 billion of unrecognized tax benefits, of which $1.8 billion, if recognized, would favorably impact the effective tax rate. The Company regularly engages in discussions and negotiations with tax authorities regarding tax matters in various jurisdictions. The Company believes it is reasonably possible that certain federal, foreign, and state tax matters may be concluded in the next 12 months. Specific positions that may be resolved include issues involving transfer pricing and various other matters. Accordingly, the Company estimates that it is reasonably possible that the unrecognized tax benefits at January 24, 2015 could be reduced by $300 million in the next 12 months.