Income Taxes (Tables)

12 Months Ended

Dec. 31, 2023

US and foreign component of income (loss) before income tax

The U.S. and foreign components of income (loss) before provision for (benefit from) income taxes for the years ended December 31, 2021, 2022 and 2023 are as follows (in millions):


	Year Ended December 31,
	2021		2022		2023
U.S.	$	(340)	$	(8,523)	$	1,525
Foreign	(685)		(903)		796
Income (loss) before income taxes and income from equity method investments	$	(1,025)	$	(9,426)	$	2,321

Components of income tax expense

The components of the provision for (benefit from) income taxes for the years ended December 31, 2021, 2022 and 2023 are as follows (in millions):


	Year Ended December 31,
	2021		2022		2023
Current
Federal	$	—	$	8	$	1
State	4		15		16
Foreign	196		237		170
Total current tax expense	200		260		187
Deferred
Federal	(76)		(251)		11
State	19		(92)		12
Foreign	(635)		(98)		3
Total deferred tax expense (benefit)	(692)		(441)		26
Total provision for (benefit from) income taxes	$	(492)	$	(181)	$	213

Reconciliation of the statutory federal income tax rate

The following is a reconciliation of the statutory federal income tax rate to our effective tax rate for the years ended December 31, 2021, 2022 and 2023:


	Year Ended December 31,
	2021		2022		2023
Federal statutory income tax rate	21.0	%	21.0	%	21.0	%
State income tax expense	(2.3)		0.8		1.2
Foreign rate differential	10.3		2.0		(0.4)
Non-deductible expenses	(5.2)		(0.7)		(0.2)
Stock-based compensation	4.5		(1.4)		(1.9)
Federal research and development credits	7.8		0.6		(7.2)
Deferred tax on investments (1)	48.7		(1.1)		(3.5)
Entity restructuring (2)	(2.0)		(12.7)		0.6
Change in unrecognized tax benefits	(27.8)		(8.9)		(6.8)
Valuation allowance	(33.7)		1.1		(2.8)
US tax on foreign income	(10.8)		0.6		4.1
Withholding taxes (3)	(0.6)		(0.3)		9.5
Tax rate change	22.4		—		—
Other interest	16.8		1.7		(4.1)
Other, net (3)	(1.1)		(0.8)		(0.3)
Effective income tax rate	48.0	%	1.9	%	9.2	%

(1) The 2021 rate impact for “Deferred tax on investments” was primarily driven by the deferred China and U.S. tax impact related to our investment in Didi and the deferred U.S. tax impact related to our investments in Aurora, Grab, and Zomato.

The 2022 rate impact for “Deferred tax on investments” was primarily driven by the deferred U.S. tax impact related to our investments in Aurora, Grab, Zomato, and Didi.

The 2023 rate impact for “Deferred tax on investments” was primarily driven by the deferred U.S. tax impact related to our investments in Aurora and Didi.

(2) To align our structure to our evolving operations, in the second and fourth quarters of 2021, we completed intercompany transfers of certain intangible assets. These intercompany transfers did not have a material impact to the financial statements.

In the fourth quarter of 2022, we transferred certain intangible assets among our wholly-owned subsidiaries to align our structure to our evolving operations. The transfer resulted in a net reduction in deferred tax assets of $1.7 billion; however, there was no financial statement expense recognized since the deferred tax asset was offset by a full valuation allowance.

(3) 2021 and 2022 amounts have been conformed to the 2023 presentation.

Deferred tax assets and liabilities

The components of deferred tax assets and liabilities as of December 31, 2022 and 2023 are as follows (in millions):


	As of December 31,
	2022		2023
Deferred tax assets
Net operating loss carryforwards	$	6,325	$	6,164
Research and development credits	1,200		1,275
Stock-based compensation	45		66
Accruals and reserves	402		440
Accrued legal	184		120
Fixed assets and intangible assets	4,425		4,135
Lease liability	478		436
Interest limitation carryforwards	858		876
Capitalized research expenses	304		771
Other	320		211
Total deferred tax assets	14,541		14,494
Less: Valuation allowance	(13,971)		(13,945)
Total deferred tax assets, net of valuation allowance	570		549
Deferred tax liabilities
Indefinite lived deferred tax liability (1)	—		114
ROU assets	354		301
Other	77		18
Total deferred tax liabilities	431		433
Net deferred tax assets (liabilities)	$	139	$	116

(1) As of December 31, 2022, the fair market value of our investments in Didi, Aurora, Grab, and Zomato decreased significantly, resulting in the reduction of indefinite-lived deferred tax liabilities.

As of December 31, 2023, the $114 million indefinite-lived deferred tax liability represents the deferred U.S. income tax expense, which will be incurred upon the eventual disposition of the shares underlying our investments in Aurora and Didi.

Changes in gross unrecognized tax benefits

The following table reflects changes in gross unrecognized tax benefits (in millions):


	Year Ended December 31,
	2021		2022		2023
Unrecognized tax benefits at beginning of year	$	2,293	$	2,657	$	3,513
Gross increases - current year tax positions	239		814		177
Gross increases - prior year tax positions	134		93		42
Gross decreases - prior year tax positions	(9)		(51)		(315)
Gross decreases - lapse of statute of limitations	—		—		(72)
Unrecognized tax benefits at end of year	$	2,657	$	3,513	$	3,345

Schedule of open tax years for major tax jurisdictions

As of December 31, 2023, the open tax years for our major tax jurisdictions are as follows:


Jurisdiction						Tax Years
U.S. Federal						2011 - 2023
U.S. States						2005 - 2023
Brazil						2017 - 2023
Netherlands						2019 - 2023
United Kingdom						2013 - 2023