INCOME TAXES
The Company has adopted ASU 2023-09, effective prospectively for the fiscal year ended December 31, 2025. ASU 2023-09 provides for enhanced income tax information primarily through changes to the rate reconciliation and income taxes paid information.
The provision for income taxes consists of the following:
2025
Current:
U.S. federal
$
U.S. state
19 
Foreign930 
Total current955 
Deferred:
U.S. federal
(87)
U.S. state
(24)
Foreign(591)
Total deferred(702)
Provision for income taxes$253 
20242023
Current:
U.S.$39 $33 
Foreign889 711 
Total current928 744 
Deferred:
U.S.(556)(27)
Foreign(115)(32)
Total deferred(671)(59)
Provision for income taxes$257 $685 
On July 4, 2025, President Trump signed into law the One Big Beautiful Bill Act ("OBBBA"). The OBBBA preserves the 21% U.S. Federal statutory tax rate and makes a favorable change to the business interest expense limitation. Further, the OBBBA also makes key elements of the Tax Cuts and Jobs Act permanent, including 100% bonus depreciation, domestic research cost expensing, and various expiring international provisions (with some modifications). Pursuant to ASC 740, changes in tax rates and tax law are required to be recognized in the period in which the legislation is enacted. The Company has completed its evaluation of the impact of this legislation and has determined that the OBBBA did not have a material impact on its 2025 financial statements.
On August 16, 2022, the U.S. enacted The Inflation Reduction Act, which included a number of additional credits and deductions for businesses and individuals. The Inflation Reduction Act also included the adoption of the Corporate Alternative Minimum Tax in 2023, which is based on financial statement book income of large corporations. To date, the impact of the Corporate Alternative Minimum Tax has been immaterial to the Company.
The geographic sources of income before income taxes consist of the following:
202520242023
U.S.$911 $1,099 $882 
Foreign1,966 2,166 1,773 
Income before income taxes
$2,877 $3,265 $2,655 
The reconciliation of the tax provision at the U.S. federal statutory rate to income tax expense is as follows:
2025
%
Income before income taxes
$2,877 
U.S. federal statutory tax rate
604 21.0 %
State and local income taxes (1)
(2)(0.1)%
Federal
Effect of cross-border tax laws
FDII deduction
(73)(2.5)%
Other37 1.3 %
Tax credits
Foreign tax credits
(46)(1.6)%
Other credits
(26)(0.9)%
Changes in valuation allowances
55 1.9 %
Nontaxable or nondeductible items
Other(4)(0.1)%
Other adjustments

Impact of transactions (2)
(210)(7.3)%
Other(12)(0.4)%
Foreign tax effects
CHINA
34 1.1 %
ITALY
State and local income taxes
39 1.4 %
Other(5)(0.2)%
SAUDI ARABIA
Withholding taxes
35 1.2 %
Other
(1)— %
SWITZERLAND
  Changes in valuation allowances
(33)(1.1)%
Taxable dividend
37 1.3 %
Other
10 0.3 %
UNITED ARAB EMIRATES
Effect of rates different than statutory
(50)(1.7)%
Other(7)(0.3)%
UNITED KINGDOM
  Changes in valuation allowances (3)
(432)(15.0)%
Other0.3 %
Other foreign jurisdictions
213 7.3 %
Changes in unrecognized tax benefits
83 2.9 %
Income tax expense
$253 8.8 %
(1)For the year ended December 31, 2025, the State and local income taxes are primarily related to the states of Louisiana, Oklahoma, Texas, and Alaska.
(2)For the year ended December 31, 2025, the Impact of transactions are associated with the pre-steps for the transactions discussed in "Note 22. Acquisitions, Dispositions, and Businesses Held for Sale."
(3)For the year ended December 31, 2025, this amount includes $308 million related to the release of a valuation allowance for certain deferred tax assets.
20242023
Income before income taxes
$3,265 $2,655 
Taxes at the U.S. federal statutory income tax rate
686 558 
Effect of foreign operations
269 112 
Tax impact of partnership structure
(40)(103)
Change in valuation allowances (1)
(625)53 
Tax expense (benefit) due to unrecognized tax benefits38 (5)
Other — net
(71)70 
Provision for income taxes
$257 $685 
Actual income tax rate7.9 %25.8 %
(1)For December 31, 2024 and 2023, this amount was reduced by $664 million and $81 million, respectively, related to the release of a valuation allowance for certain deferred tax assets.
The following table presents income taxes paid (net of refunds received) for the year ended December 31:
2025
U.S. federal
$11 
U.S. state & local
32 
Foreign
Italy- federal
286 
Brazil
101 
Germany- federal
80 
Other foreign jurisdictions
646 
Total foreign
1,113 
Total income taxes paid, net
$1,156 
Deferred income taxes reflect the net tax effects of temporary differences between the carrying amounts of assets and liabilities for financial reporting purposes and the amounts used for income tax purposes, as well as operating loss and tax credit carryforwards.
The tax effects of differences that give rise to significant portions of the deferred income tax assets and deferred income tax liabilities as of December 31 consist of the following:
20252024
Deferred tax assets:
Operating & capital loss carryforwards$3,273 $3,442 
Tax credit & other carryforwards734 772 
Investment in partnerships & subsidiaries
324 276 
Property, plant and equipment
248 250 
Employee benefits290 278 
Goodwill and other intangible assets
442 198 
Receivables127 150 
Inventory114 150 
Other
544 376 
Total deferred income tax asset 6,096 5,892 
Valuation allowances
(3,498)(3,908)
Total deferred income tax asset after valuation allowance2,598 1,984 
Deferred tax liabilities:
Indefinite-lived intangible assets
(382)(377)
Fair value of derivative financial instruments
(150)(166)
Other
(193)(240)
Total deferred income tax liability
(725)(783)
Net deferred tax asset$1,873 $1,201 
At December 31, 2025, the Company had approximately $456 million of non-U.S. tax credits and other carryforwards that may be carried forward indefinitely under applicable foreign law, $113 million of U.S. foreign tax credits, and $165 million of other U.S. Federal and state tax credits, the majority of which have expiration dates after tax year 2028 under U.S. Federal and state tax law. Additionally, the Company had $3,243 million of net operating loss carryforwards ("NOLs"), of which approximately $303 million have expiration dates within five years, $1,930 million have expiration dates between six years and 20 years, and the remainder can be carried forward indefinitely. Lastly, the Company had $30 million of capital loss carryforwards, the majority of which can be carried forward indefinitely.
The Company routinely assesses the recoverability of its deferred tax assets, giving consideration to a range of factors including, but not limited to, the pattern of historical taxable income generation, current performance, including active contractual arrangements, and the forecasted business outlook across operating jurisdictions. The ultimate realization of the deferred tax assets depends on a number of factors, including the ability to generate sufficient taxable income of the appropriate character in the future and in the appropriate taxing jurisdictions. A valuation allowance is recorded (or maintained) when it is more likely than not that some portion or all of the deferred tax assets will not be realized. The Company assessed both positive and negative evidence, with significant weight given to objective and verifiable factors, such as recent taxable income levels and credit utilization. Based on this evaluation, including consideration of our projected future taxable earnings, the Company concluded that it is more likely than not that its U.S. and U.K. deferred tax assets are recoverable. Accordingly, the Company released the associated valuation allowances, resulting in net tax benefits of $308 million and $664 million at December 31, 2025 and 2024, respectively.
At December 31, 2025, $3,498 million of valuation allowances are recorded against various deferred tax assets, primarily related to foreign operating and capital losses of $2,820 million and non-U.S. tax credit carryforwards of $438 million. The following table presents the change in the valuation allowances during the year:
20252024
Balance at the beginning of the year
$3,908 $4,416 
Releases, net of current year activity
(376)(625)
Other
(34)117 
Balance at end of year
$3,498 $3,908 
Indefinite reinvestment is determined by management's intentions concerning the future operations of the Company. In cases where repatriation would otherwise incur significant withholding or income taxes, these earnings have been indefinitely reinvested in the Company's active non-U.S. business operations. As of December 31, 2025, the cumulative amount of undistributed foreign earnings is approximately $6,622 million. Computation of the potential deferred tax liability associated with these undistributed earnings and any other basis differences is not practicable.
At December 31, 2025, the Company had $525 million of tax liabilities for total gross unrecognized tax benefits related to uncertain tax positions. In addition to these uncertain tax positions, the Company had $82 million and $49 million related to interest and penalties, respectively, for total liabilities of $656 million for uncertain positions. If the Company were to prevail on all uncertain positions, the net effect would result in an income tax benefit of approximately $612 million. The remaining $44 million is comprised of $29 million for deferred tax assets that represent tax benefits that would be received in different taxing jurisdictions or in a different character and $15 million for increased valuation allowances.
The following table presents the changes in the Company's gross unrecognized tax benefits included in the consolidated statements of financial position.
Asset / (Liability)20252024
Balance at beginning of year$(455)$(467)
Additions for tax positions of the current year(12)(17)
Additions for tax positions of prior years(193)(51)
Reductions for tax positions of prior years31 28 
Settlements with tax authorities61 24 
Lapse of statute of limitations43 28 
Balance at end of year$(525)$(455)
The Company conducts business in more than 120 countries and is subject to income taxes in most taxing jurisdictions in which it operates, each of which may have multiple open years subject to examination. All Internal Revenue Service examinations have been completed and closed through 2020 for the most significant U.S. returns. The Company believes that it has made adequate provision for all income tax uncertainties in all jurisdictions.

Historical Timeline

Fiscal YearFiled
2025Feb 5, 2026Showing above
2024Feb 4, 2025
2023Feb 5, 2024
2022Feb 14, 2023
2021Feb 11, 2022
2020Feb 25, 2021
2019Feb 13, 2020
2018Feb 19, 2019
2017Feb 23, 2018

About Income Taxes Disclosures

The income tax disclosure reveals how much a company actually pays in taxes versus what the statutory rate would predict. Analysts focus on the effective tax rate (ETR) reconciliation, which breaks down every item driving the gap between the 21% federal rate and the company's reported ETR — including R&D credits, foreign rate differentials, and state taxes. Deferred tax assets (DTAs) and their valuation allowances signal management's confidence in future profitability: a rising allowance suggests the company doubts it can use accumulated tax benefits. Uncertain tax benefit (UTB) reserves quantify exposure to IRS challenges on aggressive positions.

Key signals to watch: sudden ETR drops without clear operational reasons, large increases in valuation allowances, growing UTB balances, and significant unremitted foreign earnings. Post-TCJA, pay attention to GILTI and BEAT provisions that affect multinational tax structures. Compare the cash taxes paid (from the cash flow statement) against the income tax provision to gauge earnings quality.