Note 6. Income Taxes
The sources of income (loss) from continuing operations, before income taxes, classified between domestic entities and those entities domiciled outside of the U.S., are as follows:
Year Ended December 31,
202520242023
(Dollars in millions)
Domestic entities$(40)$(65)$(94)
Entities outside the U.S.432 408 441 
$392 $343 $347 
Tax expense (benefit)
Tax expense (benefit) consists of:
Year Ended December 31,
202520242023
(Dollars in millions)
Current tax expense (benefit):
Federal$18 $(3)$12 
State— 
Foreign54 56 50 
         Total current tax expense (benefit)$73 $54 $62 
Deferred tax expense (benefit):
Federal$(6)$(9)$(14)
State— (1)
Foreign15 17 37 
         Total deferred tax expense (benefit)$$$24 
Total income tax expense (benefit):
Federal$12 $(12)$(2)
State— 
Foreign69 73 87 
         Total income tax expense (benefit)$82 $61 $86 
Effective Tax Rate
Effective tax rate includes:
Year Ended December 31,
202520242023
AmountPercentAmountPercentAmountPercent
(Dollars in millions)
U.S. federal statutory tax rate$82 21.0 %$72 21.0 %$73 21.0 %
Domestic state and local income taxes, net of
 federal income tax effect (1)
— 0.1 %— (0.1)%0.3 %
Tax credits(1)(0.3)%(2)(0.7)%(2)(0.5)%
Nontaxable or nondeductible items— (0.1)%— (0.1)%0.3 %
Effect of cross-border tax laws (2)
   Global intangible low-taxed income17 4.3 %11 3.3 %19 5.6 %
   US effects of foreign partnership(1)(0.2)%1.8 %(1)(0.4)%
   Other(2)(0.4)%0.8 %0.2 %
Changes in valuation allowances0.8 %— — %0.4 %
   Other(4)(1.0)%0.3 %(2)(0.7)%
Foreign tax effects
   China
      Enacted changes in tax laws or rates— — %— — %28 7.9 %
      Remeasurement deferred taxes(11)(2.9)%— — %— — %
      Tax on distributions0.8 %2.5 %0.6 %
      Other1.6 %— (0.1)%(4)(1.1)%
   Switzerland
      Statutory tax rate difference between
       Switzerland and US
(30)(7.7)%(26)(7.7)%(27)(7.8)%
      Changes in valuation allowances0.2 %— 0.1 %2.3 %
      Enacted changes in tax laws or rates— — %— — %(20)(5.8)%
      Tax on distributions0.2 %2.2 %— (0.1)%
      Investment in JVs— — %1.0 %(2)(0.5)%
      Cantonal tax11 2.8 %15 4.5 %1.0 %
      Statutory impairment of investment in
       subsidiary - 2024 RTP
(7)(1.7)%— — %— — %
      Other— — %(6)(1.7)%0.8 %
   India2.0 %1.9 %0.8 %
   Thailand— — %1.3 %— — %
   Brazil
      Changes in valuation allowances— — %(19)(5.6)%— 0.1 %
      Other0.7 %(2)(0.5)%0.2 %
   Korea
      Tax refund— — %— — %(4)(1.2)%
      Other0.2 %0.3 %— (0.1)%
   Stateless— — %(6)(1.7)%— — %
   Other foreign jurisdictions1.0 %1.5 %2.6 %
Changes in unrecognized tax benefits(2)(0.5)%(22)(6.5)%(4)(1.1)%
Effective Tax Rate$82 20.9 %$61 17.8 %$86 24.8 %

(1) State taxes in Michigan and Indiana make up the majority (greater than 50 percent) of the tax effect in this category.

(2) Amounts reflected as net of related foreign tax credits.
The effective tax rate increased by 3.1 percentage points in 2025 compared to 2024. The increase was primarily due to additional unrecognized tax benefits in Switzerland and China as well as prior year benefits associated with the release
of valuation allowance related to deferred tax assets in Brazil (net of U.S. branch taxes) and prior year benefits associated with statute of limitation expiration and settlement of audits in Switzerland and Korea. These increases were partially offset by the revaluation of deferred tax assets related to intellectual property transferred within China which was subject to tax at different rates.
The effective tax rate decreased by 7.0 percentage points in 2024 compared to 2023. The decrease was primarily due to releases of reserves due to statute of limitation expirations and settlements with taxing authorities and release of valuation allowance related to deferred tax assets in Brazil (net of U.S. branch taxes). In addition, there was prior year expense due to rate change impact on deferred tax assets attributable to the certification by the Chinese government of the High and New Technology Enterprise status of the Company’s China operations, which reduced the tax rate to 15% for the respective entity. These increases were partially offset by prior year tax benefits in Switzerland due to law changes (net of valuation allowance) and in Korea for prior year tax settlements.
Deferred tax assets (liabilities)
The tax effects of temporary differences and tax carryforwards which give rise to future income tax benefits and payables are as follows:
December 31,
20252024
(Dollars in millions)
Deferred tax assets:
Intangibles and fixed assets$114 $112 
Accruals and reserves31 29 
Net operating losses and other tax attribute carryforwards42 34 
Outside basis differences29 
Other94 70 
Total deferred tax assets282 274 
Valuation allowance(37)(29)
Net deferred tax assets$245 $245 
Deferred tax liabilities:
Outside basis differences$(41)$(18)
Other(26)(45)
Total deferred tax liabilities(67)(63)
Net deferred tax asset$178 $182 

As of December 31, 2025, the Company had foreign net operating loss carryforwards of approximately $67 million with the majority in the below jurisdictions:
JurisdictionExpiration
Period
 Net Operating
Loss
Carryforwards
(Dollars in millions)
BrazilIndefinite$54 
Luxembourg203910 
OtherVarious
$67 
We also have net operating loss carryforwards in certain U.S. state jurisdictions, the tax effect of which is not significant.
We maintain a valuation allowance of $37 million against a portion of total deferred tax assets. In the event we determine that we will not be able to realize our net deferred tax assets in the future, we will reduce such amounts through an increase to tax expense in the period such determination is made. Conversely, if we determine that we will be able to
realize net deferred tax assets in excess of the carrying amounts, we will decrease the recorded valuation allowance through a reduction to tax expense in the period that such determination is made. Our valuation allowance increased $8 million from last year. Our balance sheet presents a deferred tax asset of $210 million and a deferred tax liability of $32 million after considering jurisdictional netting.

The Company does not intend to permanently reinvest the undistributed earnings of our foreign subsidiaries and have recorded a deferred tax liability, mainly consisting of withholding taxes, of $23 million as of December 31, 2025.
The following table summarizes the activity related to the Company’s uncertain tax positions (excluding interest and penalties and related tax attributes):
December 31,
202520242023
(Dollars in millions)
Change in unrecognized tax benefits:
Balance at beginning of year$48 $66 $71 
Gross increases related to current period tax positions10 
Gross increases related to prior periods tax positions— 
Gross decreases related to prior periods tax positions— — — 
Decrease related to resolutions of audits with tax authorities— (6)— 
Expiration of the statute of limitations for the assessment of taxes(11)(17)(8)
Foreign currency translation(2)— 
Balance at end of year$55 $48 $66 

As of December 31, 2025, 2024, and 2023 there were $55 million, $48 million, and $66 million, respectively, of unrecognized tax benefits that, if recognized, would be recorded as a component of tax expense.
Estimated interest and penalties related to uncertain tax benefits are classified as a component of tax expense in the Consolidated Statements of Operations and totaled $4 million of expense, $2 million of benefit, and $5 million of expense for the years ended December 31, 2025, 2024, and 2023, respectively. Accrued interest and penalties were $36 million, $32 million, and $34 million, as of December 31, 2025, 2024, and 2023, respectively.
We are currently under audit in multiple jurisdictions, primarily India for tax years 2022 through 2024 and U.S. for tax years 2018 through 2020. Based on the outcome of these examinations, or as a result of the expiration of statutes of limitations for specific jurisdictions, it is possible that certain unrecognized tax benefits for tax positions taken on previously filed tax returns will significantly change from those recorded as liabilities in our financial statements.
Income Taxes Paid (Net of Refunds Received)
Year Ended December 31,
202520242023
(Dollars in millions)
U.S. Federal$4$15$17
U.S. State & Local11
Foreign
   Brazil7
   China162011
   India9108
   Japan573
   Korea2(1)4
   Switzerland - Federal659
   Switzerland - Cantonal436
   Other81212
      Total Foreign575653
Balance at end of year$62$71$71

Historical Timeline

Fiscal YearFiled
2025Feb 19, 2026Showing above
2024Feb 20, 2025
2023Feb 15, 2024
2022Feb 14, 2023
2021Feb 14, 2022
2020Feb 16, 2021
2019Feb 27, 2020
2018Mar 1, 2019

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.