pension obligations recorded in shareholders' equity, pa rtially offset by the tax effects of net investment hedges. Prior to the passage of the U.S. Tax Act, the Company asserted that substantially all of the undistributed earnings of its foreign subsidiaries were considered indefinitely invested and, accordingly, no deferred taxes were provided. Pursuant to the provis ions of the U.S. Tax Act, these earnings were subjected to a one - time transition tax. This charge included taxes for all U.S. income taxes and for the related foreign withholding taxes for the portion of those earnings which are no longer considered indef initely invested. We have not provided deferred taxes on approximately $22 billion of earnings that are considered indefinitely invested. A reconciliation of the beginning and ending liability for uncertain tax positions is as follows: Years ended June 30 2022 2021 2020 BEGINNING OF YEAR $ 627 $ 485 $ 466 Increases in tax positions for prior years 102 157 60 Decreases in tax positions for prior years (118) (34) (21) Increases in tax positions for current year 53 60 82 Settlements with taxing authorities (42) (26) (83) Lapse in statute of limitations (17) (24) (12) Currency translation (22) 9 (7) END OF YEAR $ 583 $ 627 $ 485 Included in the total liability for uncertain tax positions at June 30, 2022, is $363 that, depending on the ultimate resolution, could impact the effective tax rate in future periods. The Company is present in approximately 70 countries and over 150 taxable jurisdictions and, at any point in time, has 40 - 50 jurisdictional audits underway at various stages of completion. We evaluate our tax positions and establish liabilities for uncert ain tax positions that may be challenged by local authorities and may not be fully sustained, despite our belief that the underlying tax positions are fully supportable. Uncertain tax positions are reviewed on an ongoing basis and are adjusted in light of changing facts and circumstances, including progress of tax audits, developments in case law and the closing of statutes of limitation. Such adjustments are reflected in the tax provision as appropriate. We have tax years open ranging from 2010 and forw ard. We are generally not able to reliably estimate the ultimate settlement amounts until the close of the audit. Based on information currently available, we anticipate that over the next 12 - month period, audit activity could be completed related to unc ertain tax positions in multiple jurisdictions for which we have accrued existing liabilities of approximately $12, including interest and penalties. We recognize the additional accrual of any possible related interest and penalties relating to the underl ying uncertain tax position in income tax expense. As of June 30, 2022, 2021 and 2020, we had accrued interest of $179, $166 and $141 and accrued penalties of $12, $10 and $17, respectively, which are not included in the above table. During the fiscal ye ars ended June 30, 2022, 2021 and 2020, we recognized $21, $38 and $39 in interest expense and $2, $6 and $1 in penalties expense, respectively. Deferred income tax assets and liabilities were comprised of the following: As of June 30 2022 2021 DEFERRED TAX ASSETS Loss and other carryforwards 914 1,030 Pension and other retiree benefits $ 740 $ 1,476 Capitalized research & development 646 358 Accrued marketing and promotion 420 424 Stock - based compensation 386 386 Fixed assets 209 223 Lease liabilities 185 196 Unrealized loss on financial and foreign exchange transactions 138 109 Advance payments 82 — Inventory 41 31 Accrued interest and taxes 22 22 Other 717 878 Valuation allowances (409) (569) TOTAL $ 4,091 $ 4,564 DEFERRED TAX LIABILITIES Goodwill and intangible assets $ 5,783 $ 5,761 Fixed assets 1,542 1,512 Other retiree benefits 1,031 645 Unrealized gain on financial and foreign exchange transactions 439 111 Lease right - of - use assets 179 191 Foreign withholding tax on earnings to be repatriated 70 108 Other 244 175 TOTAL $ 9,288 $ 8,503 Net operating loss carryforwards were $2.5 billion at June 30, 2022, and $3.0 billion at June 30, 2021. If unused, approximately $300 will expire between 2022 and 2041. The remainder, totaling $2.2 billion at June 30, 2022, may be carried forward indefinitely. The Procter & Gamble Company 49 Amounts in millions of dollars except per share amounts or as otherwise specified.