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Income Taxes
9 Months Ended
Oct. 01, 2011
Income Taxes [Abstract] 
Income Taxes

6  Income Taxes

 

The Company accounts for its uncertain tax return reporting positions in accordance with the accounting standards for income taxes, which require financial statement reporting of the expected future tax consequences of uncertain tax reporting positions on the presumption that all concerned tax authorities possess full knowledge of the reporting positions, as well as all of the pertinent facts and circumstances, but prohibit any discounting of unrecognized tax benefits associated with uncertain reporting positions for the time value of money.

The following is a summary of the activity in the Company's unrecognized tax benefits for the nine months ended October 1, 2011 and October 2, 2010 (in thousands):

   October 1, 2011 October 2, 2010
Balance at the beginning of the period $ 71,523 $ 77,924
 Realization of uncertain U.K. tax benefits   -   (9,996)
 Realization of uncertain pre-acquisition tax benefits   -   (1,500)
 Increase in other uncertain tax benefits   1,485   3,469
Balance at the end of the period $ 73,008 $ 69,897

During the three and nine months ended October 2, 2010, the Company recorded a net $8 million tax benefit in the income tax provision which represents the realization of the reserve for uncertain United Kingdom tax benefits offset by the amount of the audit settlement. Also during the nine months ended October 2, 2010, the Company recorded approximately $2 million of tax benefit in the income tax provision related to the resolution of a pre-acquisition tax exposure. The Company's uncertain tax positions are taken with respect to income tax return reporting periods beginning after December 31, 1999, which are the periods that generally remain open to income tax audit examination by the concerned income tax authorities. The Company continuously monitors the lapsing of statutes of limitations on potential tax assessments for related changes in the measurement of unrecognized tax benefits, related net interest and penalties, and deferred tax assets and liabilities. As of October 1, 2011, the Company does not expect to record any material changes in the measurement of any other unrecognized tax benefits, related net interest and penalties or deferred tax assets and liabilities due to the settlement of tax audit examinations or to the lapsing of statutes of limitations on potential tax assessments within the next twelve months.

 

The Company's effective tax rates for the three months ended October 1, 2011 and October 2, 2010 were 16.8% and 5.8%, respectively. The Company's effective tax rates for the nine months ended October 1, 2011 and October 2, 2010 were 15.6% and 12.9%, respectively. Included in the income tax provision for the nine months ended October 1, 2011 is $2 million of tax benefit related to the reversal of reserves for interest related to an audit settlement in the United Kingdom. This tax benefit decreased the Company's effective tax rate by 0.5 percentage points in the nine months ended October 1, 2011. Included in the income tax provision for the three and nine months ended October 2, 2010 is the aforementioned $8 million tax benefit related to the reversal of reserves for uncertain tax positions due to an audit settlement in the United Kingdom. This net tax benefit decreased the Company's effective tax rate for the three and nine months ended October 2, 2010 by 7.5 percentage points and 2.6 percentage points, respectively. Also included in the income tax provision for the nine months ended October 2, 2010 is the aforementioned $2 million of tax benefit related to the resolution of a pre-acquisition tax exposure. This tax benefit decreased the Company's effective tax rate by 0.5 percentage points in the nine months ended October 2, 2010. The remaining differences between the effective tax rates for the three and nine months ended October 1, 2011 as compared to the three and nine months ended October 2, 2010 were primarily attributable to differences in the proportionate amounts of pre-tax income recognized in jurisdictions with different effective tax rates.