In 2014, income tax expense in the U.S. was reduced by $179 for release of valuation allowances for income forecasted to  be realized in 2015 in connection with certain tax planning actions expected to be completed in 2015. No tax benefit has been  recognized on a charge of $80 in 2014 relating to the divestiture of our  Venezuela operations due to the existence of a valuation  allowance, resulting in an increase in the ef fective tax rate. Valuation allowance releases of $34 in Canada and $20 in the U.K.  favorably impacted the 2012 ef fective rate.  In 2013, income tax expense was reduced by $7 for the impact of new tax legislation and tax rate changes outside the U.S.  Additionally, non-U.S. income in each of the three years contributed to an ef fective tax rate of less than  35% due to lower  statutory tax rates in the countries where we operate outside the U.S. Foreign income repatriation  — We provide for U.S. federal income and non-U.S. withholding taxes on the earnings of our non- U.S. operations that are not considered to be permanently reinvested.  Accordingly, we continue to analyze and adjust the  estimated tax impact of the income and non-U.S. withholding liabilities based on the amount and source of these earnings.  We  recognized net expense of $3, $8 and $7 for 2014, 2013 and 2012 related to future income taxes and non-U.S. withholding  taxes on repatriations from operations that are not permanently reinvested.  We also accrued withholding taxes of $7, $13 and  $10 during 2014, 2013 and 2012 related to the actual transfer of funds to the U.S. and between foreign subsidiaries. The earnings of our non-U.S. subsidiaries will likely be repatriated to the U.S. in the form of repayments of intercompany  borrowings and distributions from earnings. Certain of our international operations had intercompany loan obligations to the  U.S. totaling $574 at the end of 2014. Included in this amount are intercompany loans and related interest accruals with an  equivalent value of $36 which are denominated in a foreign currency and considered to be permanently invested. Valuation allowance adjustments  — We have generally not recognized tax benefits on losses generated in several entities,  including in the U.S., where the recent history of operating losses does not allow us to satisfy the “more likely than not”  criterion for the recognition of deferred tax assets. Consequently , there is no income tax expense or benefit recognized on the  pre-tax income or losses in these jurisdictions as valuation allowances are adjusted to of fset the associated tax expense or  benefit. At December 31, 2014, we continue to carry a valuation allowance against certain deferred tax assets in the U.S. because,  on a more likely than not basis, we have concluded that a significant portion of the U.S. deferred tax assets are not expected to  be realized. When evaluating the continued need for this valuation allowance we consider all components of comprehensive  income, and we weight the positive and negative evidence, putting greater reliance on objectively verifiable historical evidence  than projections of future profitability that are dependent on actions that have not taken place as of the assessment date.  We also  consider the pro forma ef fects on historical profitability of actions that have occurred through the year of assessment and  objectively verifiable effects of material forecasted events that have a sustained ef fect on future profitability , as well as the  effect on historical profits of nonrecurring events.  These effects included items such as the lost future interest income resulting  from the prepayment on and subsequent sale of the payment-in-kind callable note receivable and the additional interest expense  resulting from the $750 senior unsecured notes payable issued in July 2013. We also consider the pro forma historical and  prospective effects of tax planning strategies expected to be implemented. Our 2014 assessment considered the ef fects of  certain tax planning actions which will be completed in 2015.  A sustained return to profitability , after giving pro forma ef fect to  implemented actions, planned actions and nonrecurring events, along with positive expectations for future profitability are  necessary for a determination that a valuation allowance should be released. In 2015, we expect to generate taxable income associated with certain tax planning actions.The gain and related income  associated with these actions are estimated to generate tax of  $179. Although the actual gain and operating income may dif fer  from the current estimate, we concluded that they were objectively verifiable and reasonably estimated. While our U.S.  operations have experienced improved profitability in recent years, our analysis of the income of the U.S. operations, as  adjusted for pro forma ef fects of developments through 2014 and planned future actions, demonstrates historical losses as of  December 31, 2014 with an uncertain forecast of near break-even results.  Therefore, we have not achieved a level of sustained  profitability that would, in our judgment, support a release of valuation allowance at December 31, 2014 beyond the  $179  relating to the income previously noted. While there may be opportunity for our U.S. operations to generate profits in the  future, our near-term level of profitability is uncertain.The potential long-term profitability cannot be given as much weight in  our analysis given the objectively verifiable lack of sustained pro forma historical profitability and uncertainty associated with  the future U.S. operations. To the extent that our operations in the U.S., after giving ef fect to the planned aforementioned tax  actions, are profitable in 2015 and our projections of profitability beyond 2015 are suf ficiently positive based upon objective  and verifiable assumptions, it is reasonably possible that we could release up to  $500 of the remaining valuation allowance  against our U.S. deferred tax assets in the next twelve months. 79