Income Taxes

12 Months Ended

Dec. 31, 2023

Income Tax Disclosure [Abstract]

Income Taxes

(17)Income Taxes

A reconciliation of the Company’s effective tax rate to the U.S. federal statutory rate is as follows:

	Years Ended December 31,
	2023			2022			2021
U.S. federal income tax statutory rate		21.0	%		21.0	%		21.0	%
Goodwill impairment		(18.4	)		—			—
Federal tax credits		0.9			(1.5	)		(0.7	)
State income taxes, net of federal benefit		0.5			(0.3	)		1.5
Effect of foreign operations taxed at various rates		0.9			(6.8	)		(4.5	)
Executive compensation		(0.1	)		1.5			0.9
Foreign derived intangible income deduction		0.6			(4.8	)		(1.7	)
Global intangible low taxed income, net of foreign tax credits		(0.5	)		3.6			0.5
Stock-based compensation		(0.4	)		0.3			(0.5	)
Deferred tax asset valuation allowance		(0.1	)		(0.4	)		(0.8	)
Change in income tax reserves (including interest)		(0.5	)		0.8			(0.6	)
Withholding taxes on foreign dividends, net of foreign tax credits		(0.4	)		10.7			1.5
Other		1.0			(1.0	)		0.4
		4.5	%		23.1	%		17.1	%

The components of (loss) income before income taxes and the related (benefit) provision for income taxes consist of the following:

	Years Ended December 31,
	2023			2022			2021
(Loss) income before income taxes:
United States	$	(760	)	$	(90	)	$	249
Foreign		(1,168	)		523			416
	$	(1,928	)	$	433		$	665
Current taxes:
United States	$	21		$	40		$	38
State		6			7			10
Foreign		120			99			64
		147			146			112
Deferred taxes:
United States		(130	)		(68	)		5
State		(18	)		(8	)		2
Foreign		(86	)		30			(5	)
		(234	)		(46	)		2
(Benefit) provision for income taxes	$	(87	)	$	100		$	114

The significant components of the deferred tax assets and deferred tax liabilities are as follows:

	December 31,
	2023			2022
Deferred tax assets:
Interest, loss, and credit carryforwards	$	278		$	224
Capitalized research and development		98			31
Inventory and warranty reserves		54			50
Lease liability		51			55
Accrued expenses and other reserves		23			22
Stock-based compensation		4			3
Loan costs		—			9
Other		11			5
Total deferred tax assets		519			399
Valuation allowance		(190	)		(181	)
Net deferred tax assets	$	329		$	218
Deferred tax liabilities:
Acquired intangible assets and goodwill	$	(637	)	$	(781	)
Depreciation and amortization		(56	)		(62	)
Right-of-use asset		(49	)		(55	)
Foreign withholding taxes		(50	)		(56	)
Loan costs		(24	)		—
Unrealized gain		—			(14	)
Total deferred tax liabilities		(816	)		(968	)
Net deferred tax liabilities	$	(487	)	$	(750	)

As of December 31, 2023, the Company had U.S. federal and state as well as foreign gross research and other tax credit carryforwards of $41. Included in the total carryforwards are $11 of credits that can be carried forward indefinitely while the remaining credits expire at various dates through 2037. The Company also had U.S. federal and state as well as foreign gross net operating loss and capital loss carryforwards of $349. Included in the total carryforwards are $55 of losses that can be carried forward indefinitely while the remaining losses expire at various dates through 2041. The Company has $688 of foreign interest carryforwards that can be carried forward indefinitely.

Although the Company believes that its tax positions are consistent with applicable U.S. federal, state and international laws, it maintains certain income tax reserves as of December 31, 2023 in the event its tax positions were to be challenged by the applicable tax authority and additional tax assessed upon audit.

A reconciliation of the beginning and ending amount of gross unrecognized tax benefits, excluding interest and penalties, is as follows:

	Years Ended December 31,
	2023			2022			2021
Balance at beginning of year	$	83		$	43		$	47
Increases (decreases) for tax positions taken during prior years		(5	)		35			—
Increases for tax positions taken during the current year		12			9			2
Reductions related to expiration of statutes of limitations and      audit settlements		(4	)		(4	)		(6	)
Balance at end of year	$	86		$	83		$	43

The net increase in gross unrecognized tax benefits in 2023 was primarily due to the addition of unrecognized U.S. federal tax credits.

The Company accrues interest and, if applicable, penalties for any uncertain tax positions. Interest and penalties are classified as a component of income tax (benefit) expense. As of December 31, 2023, 2022 and 2021, the Company accrued interest on unrecognized tax benefits of approximately $7, $6 and $1, respectively.

Over the next 12 months, it is reasonably possible that the Company may recognize approximately $12 of previously net unrecognized tax benefits, excluding interest and penalties, related to various U.S. federal and state as well as foreign tax positions, primarily due to the expiration of statutes of limitations.

The Company is subject to examination by U.S. federal and state as well as foreign tax authorities. The U.S. federal statute of limitations remains open for tax years 2020 through the present. The statute of limitations for the Company’s tax filings in other jurisdictions varies between fiscal years 2017 through present. The Company also has certain U.S. federal and state as well as foreign tax loss and credit carryforwards that are open for examination for tax years 2003 to the present. In addition, the 2017 U.S. federal transition tax remains open for examination.

On a quarterly basis, the Company evaluates both positive and negative evidence that affects the realizability of its net deferred tax assets and assesses the need for a valuation allowance. The future benefit to be derived from its deferred tax assets is dependent upon its ability to generate sufficient future taxable income to realize the assets.

During 2023, the Company increased its valuation allowance by $9, primarily related to the valuation allowance recorded in connection with foreign interest and net operating loss carryforwards. During 2022, the Company increased its valuation allowance by $155, primarily related to the valuation allowance recorded for foreign interest and net operating loss carryforwards associated with the Atotech Acquisition.

Deferred taxes have been recorded related to historical outside basis differences, primarily unremitted earnings, of certain of the Company’s foreign subsidiaries. During 2023, the Company recorded a tax benefit of $3 related to such taxes for prior periods.