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Income Taxes
12 Months Ended
Dec. 31, 2024
Income Tax Disclosure [Abstract]  
Income taxes Income taxes
Income before income taxes is comprised of the following components:
For Years Ended December 31,
202420232022
U.S.$4,438 $6,445 $9,122 
Non-U.S.1,015 973 910 
Total$5,453 $7,418 $10,032 
Provision for income taxes is comprised of the following components:
For Years Ended December 31,
202420232022
CurrentDeferredTotalCurrentDeferredTotalCurrentDeferredTotal
U.S. federal$605 $(139)$466 $943 $(277)$666 $1,235 $(223)$1,012 
Non-U.S.244 (71)173 240 (22)218 212 32 244 
U.S. state15  15 24 — 24 27 — 27 
Total$864 $(210)$654 $1,207 $(299)$908 $1,474 $(191)$1,283 
Principal reconciling items from the U.S. statutory income tax rate to the effective tax rate (provision for income taxes as a percentage of income before income taxes) are as follows:
For Years Ended December 31,
202420232022
U.S. statutory income tax rate21.0 %21.0 %21.0 %
Foreign derived intangible income(6.1)(6.8)(7.0)
Stock compensation(2.1)(1.0)(0.7)
R&D tax credit(2.0)(1.3)(0.9)
Changes in uncertain tax positions0.1 — 0.1 
Other1.1 0.3 0.3 
Effective tax rate12.0 %12.2 %12.8 %
The earnings represented by non-cash operating assets, such as fixed assets and inventory, will continue to be permanently reinvested outside the United States. Provisions of the U.S. Tax Cuts and Jobs Act, such as the one-time tax on indefinitely reinvested earnings and the global intangible low-taxed income (GILTI) tax for years beginning in 2018, eliminate any additional U.S. taxation resulting from repatriation of earnings of non-U.S. subsidiaries to the United States. Consequently, no U.S. tax provision has been made for the future remittance of these earnings. However, withholding or distribution taxes in certain non-U.S. jurisdictions will be incurred upon repatriation of available cash to the United States. A provision has been made for deferred taxes on these undistributed earnings to the extent that repatriation of the available cash to the United States is expected to result in a tax liability. As of December 31, 2024, we have no basis differences that would result in material unrecognized deferred tax liabilities.
We have made an allowable policy election to account for the effects of GILTI as a component of income tax expense in the period in which the tax is incurred.
The primary components of deferred tax assets and liabilities are as follows:
December 31,
20242023
Deferred tax assets:
Capitalized R&D$1,076 $750 
Accrued expenses297 236 
Deferred loss and tax credit carryforwards216 205 
Stock compensation186 163 
Inventories105 104 
Retirement costs for defined benefit and retiree health care17 37 
Other23 47 
Total deferred tax assets, before valuation allowance1,920 1,542 
Valuation allowance(212)(198)
Total deferred tax assets, after valuation allowance1,708 1,344 
Deferred tax liabilities:
Property, plant and equipment(441)(592)
CHIPS Act incentives(336)— 
International earnings(33)(33)
Acquisition-related intangibles and fair-value adjustments(6)(14)
Other(9)(11)
Total deferred tax liabilities(825)(650)
Net deferred tax asset$883 $694 
The deferred tax assets and liabilities based on tax jurisdictions are presented on our Consolidated Balance Sheets as follows:
December 31,
20242023
Deferred tax assets$936 $757 
Deferred tax liabilities(53)(63)
Net deferred tax asset$883 $694 
We make an ongoing assessment regarding the realization of U.S. and non-U.S. deferred tax assets. This assessment is based on our evaluation of relevant criteria, including the existence of deferred tax liabilities that can be used to absorb deferred tax assets, taxable income in prior carryback years and expectations for future taxable income. Valuation allowances increased $14 million, $9 million and $1 million in 2024, 2023 and 2022, respectively. These changes had no impact to net income in 2024, 2023 or 2022.
We have no material tax loss carryforwards as of December 31, 2024.
Cash payments made for income taxes, net of refunds, were $451 million, $1.35 billion and $1.48 billion in 2024, 2023 and 2022, respectively. In 2024, the total cash benefit related to the CHIPS Act ITC was $588 million, which was used to reduce our income taxes payable.
Uncertain tax positions
We operate in a number of tax jurisdictions, and our income tax returns are subject to examination by tax authorities in those jurisdictions who may challenge any item on these tax returns. Because the matters challenged by authorities are typically complex, their ultimate outcome is uncertain. Before any benefit can be recorded in our financial statements, we must determine that it is “more likely than not” that a tax position will be sustained by the appropriate tax authorities. We recognize accrued interest related to uncertain tax positions and penalties as components of OI&E.
The changes in the total amounts of uncertain tax positions are as follows:
202420232022
Balance, January 1$82 $82 $69 
Additions based on tax positions related to the current year3 
Additions for tax positions of prior years — 10 
Reductions for tax positions of prior years (3)— 
Balance, December 31$85 $82 $82 
Interest expense recognized in the year ended December 31$(5)$(9)$(1)
Interest payable as of December 31$15 $10 $
The liability for uncertain tax positions is a component of other long-term liabilities on our Consolidated Balance Sheets.
All of the $85 million and $82 million liabilities for uncertain tax positions as of December 31, 2024 and 2023, respectively, are comprised of positions that, if recognized, would lower the effective tax rate. If these liabilities are ultimately realized, no existing deferred tax assets in 2024 or 2023 would also be realized.
As of December 31, 2024, the statute of limitations remains open for U.S. federal tax returns for 2018 and following years. Certain tax treaty procedures for relief from double taxation remain pending for U.S. federal tax returns for the years 2018 through 2022.
In non-U.S. jurisdictions, the years open to audit represent the years still open under the statute of limitations. With respect to major jurisdictions outside the United States, our subsidiaries are no longer subject to income tax audits for years before 2012.