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Income Taxes
12 Months Ended
Dec. 31, 2014
Income Taxes  
Income Taxes

 

16. Income Taxes

        Income taxes relating to income from continuing operations consisted of the following:

                                                                                                                                                                                    

 

 

Year Ended December 31,

 

 

 

2014

 

2013

 

2012

 

Current:

 

 

 

 

 

 

 

 

 

 

Federal

 

$

52.6

 

$

7.3

 

$

(16.4

)

State and local

 

 

7.9

 

 

5.1

 

 

1.2

 

Foreign

 

 

42.2

 

 

33.9

 

 

26.5

 

​  

​  

​  

​  

​  

​  

Total current

 

 

102.7

 

 

46.3

 

 

11.3

 

​  

​  

​  

​  

​  

​  

Deferred:

 

 

 

 

 

 

 

 

 

 

Federal

 

 

42.9

 

 

71.3

 

 

70.1

 

State and local

 

 

9.3

 

 

9.5

 

 

11.8

 

Foreign

 

 

(1.7

)

 

(3.2

)

 

1.4

 

​  

​  

​  

​  

​  

​  

Total deferred

 

 

50.5

 

 

77.6

 

 

83.3

 

​  

​  

​  

​  

​  

​  

Income taxes relating to continuing operations

 

$

153.2

 

$

123.9

 

$

94.6

 

​  

​  

​  

​  

​  

​  

​  

​  

​  

​  

​  

​  

​  

        Income taxes relating to income from continuing operations varied from the U.S. federal statutory income tax rate due to the following:

                                                                                                                                                                                    

 

 

Year Ended December 31,

 

 

 

2014

 

2013

 

2012

 

Income taxes relating to continuing operations at federal statutory rate of 35%

 

$

161.7

 

$

131.0

 

$

101.8

 

State and local income taxes, net of federal taxes

 

 

11.0

 

 

8.7

 

 

7.1

 

Non-U.S. income taxed at other rates

 

 

(19.0

)

 

(16.1

)

 

(12.6

)

Other

 

 

(0.5

)

 

0.3

 

 

(1.7

)

​  

​  

​  

​  

​  

​  

Income taxes relating to continuing operations

 

$

153.2

 

$

123.9

 

$

94.6

 

​  

​  

​  

​  

​  

​  

​  

​  

​  

​  

​  

​  

​  

        The components of deferred tax assets and liabilities as of December 31, 2014 and 2013 were as follows:

                                                                                                                                                                                    

 

 

2014

 

2013

 

Deferred Tax Assets

 

 

 

 

 

 

 

Accrued liabilities

 

$

72.1

 

$

61.8

 

Net operating loss carryforwards

 

 

16.0

 

 

13.7

 

Interest rate swap

 

 

 

 

3.1

 

Other

 

 

8.4

 

 

12.4

 

​  

​  

​  

​  

Total deferred tax assets

 

 

96.5

 

 

91.0

 

Valuation allowance

 

 

(18.2

)

 

(14.6

)

​  

​  

​  

​  

Net deferred tax assets

 

 

78.3

 

 

76.4

 

​  

​  

​  

​  

Deferred Tax Liabilities

 

 

 

 

 

 

 

Depreciation and amortization

 

 

(187.6

)

 

(175.9

)

Partnership investments

 

 

(253.0

)

 

(219.0

)

Convertible notes

 

 

(10.0

)

 

(12.5

)

Other

 

 

(3.5

)

 

(1.3

)

​  

​  

​  

​  

Total deferred tax liabilities

 

 

(454.1

)

 

(408.7

)

​  

​  

​  

​  

Net deferred tax liabilities

 

$

(375.8

)

$

(332.3

)

​  

​  

​  

​  

​  

​  

​  

​  

​  

        We do not provide for U.S. taxes relating to undistributed earnings or losses of our non-U.S. subsidiaries. Income from continuing operations before income taxes of non-U.S. subsidiaries (which subsidiaries are predominately in the U.K.) was $170.6 million, $134.7 million, and $117.0 million during 2014, 2013, and 2012, respectively. It is our belief that such earnings will be indefinitely reinvested in the companies that produced them. As of December 31, 2014, we have not provided U.S. federal income taxes on a total temporary difference of $711.0 million related to the excess of financial reporting basis over tax basis in the non-U.S. subsidiaries.

        As of December 31, 2014, we have $96.9 million of state net operating loss carryforwards in the U.S. that expire at various dates beginning in 2015 through 2034, U.S. federal and state credit carryforwards of $3.4 million that will not expire, U.K. net operating loss carryforwards of $0.2 million that will not expire, U.K. capital loss carryforwards of $5.2 million that will not expire, German net operating loss carryforwards of $18.2 million that will not expire, Australia net operating loss carryforwards of $9.5 million that will not expire and Italian net operating loss carryforwards of $0.1 million that will not expire. We utilized $53.1 million of state net operating loss carryforwards in the U.S. in 2014.

        A valuation allowance of $2.6 million has been recorded against the state net operating loss carryforwards in the U.S. and a valuation allowance of $0.1 million has been recorded against the state credit carryforwards in the U.S. as of December 31, 2014. A valuation allowance of $7.3 million has been recorded against German net operating losses and other deferred tax assets and a valuation allowance of $8.2 million has been recorded against U.K. deferred tax assets related to buildings as of December 31, 2014.

        Generally accepted accounting principles relating to uncertain income tax positions prescribe a minimum recognition threshold a tax position is required to meet before being recognized, and provides guidance on the derecognition, measurement, classification, and disclosure relating to income taxes. The movement in uncertain tax positions for the years ended December 31, 2014, 2013, and 2012 were as follows:

                                                                                                                                                                                    

 

 

2014

 

2013

 

2012

 

Uncertain tax positions—January 1

 

$

14.0

 

$

14.7

 

$

14.9

 

Gross increase—tax position in prior periods

 

 

0.2

 

 

0.3

 

 

1.3

 

Gross decrease—tax position in prior periods

 

 

(0.6

)

 

(0.8

)

 

(0.8

)

Gross increase—current period tax position

 

 

0.1

 

 

0.1

 

 

 

Settlements

 

 

 

 

(0.4

)

 

(0.9

)

Lapse in statute of limitations

 

 

 

 

(0.1

)

 

(0.3

)

Foreign exchange

 

 

(0.6

)

 

0.2

 

 

0.5

 

​  

​  

​  

​  

​  

​  

Uncertain tax positions—December 31

 

$

13.1

 

$

14.0

 

$

14.7

 

​  

​  

​  

​  

​  

​  

​  

​  

​  

​  

​  

​  

​  

        We have elected to include interest and penalties in our income tax expense. The total interest and penalties included within uncertain tax positions at December 31, 2014 was $2.7 million. We do not expect a significant change to the amount of uncertain tax positions within the next twelve months. Our U.S. federal returns remain open to examination for 2012 and 2013 and various non-U.S. and U.S. state jurisdictions are open for periods ranging from 2002 through 2013. The portion of the total amount of uncertain tax positions as of December 31, 2014 that would, if recognized, impact the effective tax rate was $12.9 million.

        We have classified our tax reserves as a long-term obligation on the basis that management does not expect to make payments relating to those reserves within the next twelve months.