Income Taxes

12 Months Ended

Dec. 31, 2019

Income Taxes [Abstract]

Income Taxes

11. Income Taxes

Consolidated income before provision for income taxes consists of the following for the years ended December 31, 2019, 2018 and 2017 (U.S. dollars in thousands):

	2019		2018			2017
U.S.	$	24,211	$	(67,087	)	$	1,135
Foreign		230,961		286,753			264,432
Total	$	255,172	$	219,666		$	265,567

The provision for current and deferred taxes for the years ended December 31, 2019, 2018 and 2017 consists of the following (U.S. dollars in thousands):

	2019			2018			2017
Current
Federal	$	—		$	—		$	(14,358	)
State		2,213			652			1,814
Foreign		79,694			116,303			104,688
		81,907			116,955			92,144
Deferred
Federal		(8,878	)		(17,836	)		45,593
State		(473	)		(1,974	)		(2,273	)
Foreign		9,063			634			666
		(288	)		(19,176	)		43,986
Provision for income taxes	$	81,619		$	97,779		$	136,130

The principal components of deferred taxes are as follows (U.S. dollars in thousands):

	Year Ended December 31,
	2019			2018
Deferred tax assets:
Inventory differences	$	5,040		$	4,257
Foreign tax credit and other foreign benefits		69,820			62,521
Stock-based compensation		7,441			7,893
Accrued expenses not deductible until paid		35,374			40,509
Foreign currency exchange		163			1,023
Net operating losses		6,341			4,522
Capitalized research and development		18,716			11,988
Interest expense limitation – 163(j)		—			847
R&D credit carryforward		881			807
Other		37			339
Gross deferred tax assets		143,813			134,706
Deferred tax liabilities:
Foreign currency exchange		721			124
Foreign withholding taxes		20,986			21,524
Intangibles step-up		4,958			5,763
Overhead allocation to inventory		3,611			2,857
Amortization of intangibles		15,393			15,812
Other		1,063			833
Gross deferred tax liabilities		46,732			46,913
Valuation allowance		(77,042	)		(68,697	)
Deferred taxes, net	$	20,039		$	19,096

At December 31, 2019, the Company had foreign operating loss carryforwards of $18.2 million for tax purposes, which will be available to offset future taxable income. If not used, $6.3 million of carryforwards will expire between 2020 and 2029, while $11.9 million do not expire. A valuation allowance has been placed on foreign operating loss carryforwards of $18.2 million, tax effected the valuation on the net operating loss is $6.3 million. In addition, a valuation allowance has been recorded on the foreign tax credit carryforward, and the R&D credit carryforward of $70.7 million which will expire between 2026 and 2029.

The Company uses the tax law ordering approach when determining when excess tax benefits have been realized.

The valuation allowances have been recognized for the foreign tax credit, the foreign net operating loss carryforwards, and the R&D credit carryforward.  The valuation allowances were recognized for assets which it is more likely than not some portion or all of the deferred tax asset will not be realized. In making such determination, the Company considers all available positive and negative evidence, including future reversals of existing taxable temporary difference, projected future taxable income, tax planning strategies and recent financial operations. When the Company determines that there is sufficient positive evidence to utilize the foreign tax credits, the foreign net operating losses, or the R&D credit carryforward, the valuation will be released which would reduce the provision for income taxes.

The deferred tax asset valuation adjustments for the years ended December 31, 2019, 2018 and 2017 are as follows (U.S. dollars in thousands):

	Year Ended December 31,
	2019			2018			2017
Balance at the beginning of period	$	68,697		$	56,906		$	9,137
Additions charged to cost and expenses		10,913	(1)		27,902	(4)		53,983	(6)
Decreases		(3,343	)(2)		(16,215	)(5)		(6,400	)(7)
Adjustments		775	(3)		104	(3)		186	(3)
Balance at the end of the period	$	77,042		$	68,697		$	56,906

(1) Increase in valuation is due primarily to $9.8 million that was recorded on the foreign tax credit carryforward. The additional amount is due to net operating losses in foreign markets.

(2) The decrease was due primarily to the utilization of foreign tax credits, and expiration of foreign net operating losses.

(3) Represents the net currency effects of translating valuation allowances at current rates of exchange.

(4) Increase in valuation is due primarily to the $27.2 million that was recorded on the foreign tax credit carryforward. The additional amount is due to net operating losses in foreign markets

(5) The decrease was due primarily to the utilization of foreign tax credits. Decrease is due primarily to the write-off of Brazil deferred tax assets, which had no impact to the income statement, as a valuation allowance had been previously recorded against the asset.

(6) Increase in valuation allowance is due primarily to the $52.0 million that was recorded on the foreign tax credit carryforward. The additional amount is due to net operating losses in foreign markets.

(7) Decrease is due primarily to the write-off of Brazil deferred tax assets, which had no impact to the income statement, as a valuation allowance had been previously recorded against the asset.

The components of deferred taxes, net on a jurisdiction basis are as follows (U.S. dollars in thousands):

	Year Ended December 31,
	2019		2018
Net noncurrent deferred tax assets	$	30,780	$	37,332
Net noncurrent deferred tax liabilities		10,741		18,236
Deferred taxes, net	$	20,039	$	19,096

The Company is subject to regular audits by federal, state and foreign tax authorities. These audits may result in proposed assessments that may result in additional tax liabilities.

The actual tax rate for the years ended December 31, 2019, 2018 and 2017 compared to the statutory U.S. Federal tax rate is as follows:

	Year Ended December 31,
	2019			2018			2017
Income taxes at statutory rate		21.00	%		21.00	%		35.00	%
Indefinite reinvestment		—			(2.73	)%		2.75	%
Excess tax benefit from equity award		0.02	%		(1.41	)%		(2.38	)%
Non-U.S. income taxed at different rates		3.09	%		7.37	%		—
Foreign withholding taxes		4.10	%		7.68	%		—
Change in reserve for uncertain tax positions		1.07	%		3.68	%		—
Non-deductible expenses		—			—			0.17	%
Controlled foreign corporation losses		—			—			(0.13	)%
Valuation allowance recognized foreign tax credit & others		2.56	%		5.54	%		19.59	%
Write-off outside basis DTL		—			—			(2.89	)%
Revaluation of deferred taxes		—			1.61	%		(1.28	)%
Foreign-Derived Intangible Income (FDII)		(0.70	)%		—			—
Other		0.85	%		1.77	%		0.43	%
		31.99	%		44.51	%		51.26	%

The effective rate for 2018 was significantly impacted by the restructuring and impairment expenses incurred in Q4 of 2018, as well as additional valuation allowances related to foreign tax credits. The effective tax rate for 2017 was impacted largely due to the Tax Reform Act.

The cumulative amount of undistributed earnings of the Company’s non-U.S. Subsidiaries held for indefinite reinvestment is approximately $60.0 million, at December 31, 2019.  If this amount were repatriated to the United States, the amount of incremental taxes would be approximately $6.0 million.