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Income Taxes
9 Months Ended
Jun. 30, 2013
Income Tax Disclosure [Abstract]  
Income Taxes
Income Taxes
For the three and nine months ended June 30, 2013, the Company's effective tax rates of 23.7% and 55.1% were negatively impacted by, pretax losses in the United States and some foreign jurisdictions for which the Company concluded that the tax benefits are not more-likely-than-not realizable, deferred income tax expense due to changes in the tax bases of indefinite lived intangibles that are amortized for tax purposes, but not for book purposes, and tax expense on income in certain other foreign jurisdictions that will not be creditable in the United States. Partially offsetting these factors in the nine months ended June 30, 2013 was the release of U.S. valuation allowances totaling $49.3 in deferred tax assets that Spectrum Brands has determined are more-likely-than-not realizable as a result of a recent acquisition and $81.9 of income resulting from a decrease in the fair value of the equity conversion feature of preferred stock which is not taxable. Net operating loss (“NOL”) and tax credit carryforwards of HGI and Spectrum Brands are subject to full valuation allowances and those of FGL are subject to partial valuation allowances, as the Company concluded all or a portion of the associated tax benefits are not more-likely-than-not realizable. Utilization of NOL and other tax credit carryforwards of HGI, Spectrum Brands and FGL are subject to limitations under Internal Revenue Code (“IRC”) Sections 382 and 383. Such limitations result from ownership changes of more than 50 percentage points over a three-year period.
For the three months ended July 1, 2012, the Company's effective tax rate of 5.0% was lower than the United States Federal statutory rate of 35% and, for the nine months ended July 1, 2012, the Company recorded tax expense at the rate of (356.3)% despite incurring a pretax loss, primarily as a result of: (i) $125.5 of expense in the three month period for an increase in the fair value of the equity conversion feature of preferred stock, for which no tax benefit is available; (ii) pretax losses in the United States and some foreign jurisdictions for which the Company concluded that the tax benefits are not more-likely-than-not realizable; (iii) deferred income tax expense due to changes in the tax bases of indefinite lived intangibles that are amortized for tax purposes, but not for book purposes; (iv) and tax expense on income in certain other foreign jurisdictions that will not be creditable in the United States. Partially offsetting these factors in the nine months ended July 1, 2012 was: (i) a $19.0 release by FGL of valuation allowances on deferred tax assets primarily as a result of revised projections in connection with the regulatory non-approval of a proposed reinsurance transaction; (ii) a $41.0 gain on a contingent purchase price reduction receivable for which no tax provision is necessary; and (iii) a $13.9 release by Spectrum Brands of valuation allowances on deferred tax assets as a result of an acquisition.

The Company recognizes in its consolidated financial statements the impact of a tax position if it concludes that the position is more likely than not sustainable upon audit, based on the technical merits of the position. At June 30, 2013 and September 30, 2012, the Company had $9.0 and $5.9, respectively, of unrecognized tax benefits related to uncertain tax positions. The Company also had approximately $3.8 and $3.6, respectively, of accrued interest and penalties related to the uncertain tax positions at those dates. Interest and penalties related to uncertain tax positions are reported in the financial statements as part of income tax expense. As of June 30, 2013, certain of the Company’s legal entities in various jurisdictions are undergoing income tax audits. The Company cannot predict the ultimate outcome of the examinations; however, it is reasonably possible that during the next 12 months some portion of previously unrecognized tax benefits could be recognized.