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Income Taxes (Tables)
12 Months Ended
Dec. 31, 2017
Income Tax Disclosure [Abstract]  
Schedule of Provision (Benefit) for Income Taxes

The components of the Company’s provision (benefit) for income taxes for the years ended December 31, 2017, 2016 and 2015, and a reconciliation of the U.S. federal statutory income tax rate to the Company’s effective tax rates for such years, are shown below.

 

 

 

Year Ended December 31,

 

 

 

2017

 

 

2016

 

 

2015

 

Current:

 

 

 

 

 

 

 

 

 

 

 

 

Federal

 

$

349

 

 

$

1,766

 

 

$

8,177

 

Foreign

 

 

64,119

 

 

 

54,253

 

 

 

78,086

 

State and local (primarily UBT)

 

 

(32

)

 

 

4,090

 

 

 

4,970

 

Total current

 

 

64,436

 

 

 

60,109

 

 

 

91,233

 

Deferred:

 

 

 

 

 

 

 

 

 

 

 

 

Federal

 

 

480,085

 

 

 

50,602

 

 

 

(988,900

)

Foreign

 

 

12,928

 

 

 

1,354

 

 

 

(3,960

)

State and local

 

 

8,150

 

 

 

11,704

 

 

 

(107,925

)

Total deferred

 

 

501,163

 

 

 

63,660

 

 

 

(1,100,785

)

Total

 

$

565,599

 

 

$

123,769

 

 

$

(1,009,552

)

 

Schedule of Reconciliation of U.S. Federal Statutory Income Tax Rate to Effective Tax Rates

 

 

 

Year Ended December 31,

 

 

 

2017

 

 

2016

 

 

2015

 

U.S. federal statutory income tax rate

 

 

35.0

%

 

 

35.0

%

 

 

35.0

%

U.S. tax reform

 

 

43.4

 

 

 

-

 

 

 

-

 

Foreign source income not subject to U.S.

   income tax

 

 

(4.2

)

 

 

(9.3

)

 

 

419.4

 

Change in U.S. federal valuation allowance

 

 

(3.4

)

 

 

(3.6

)

 

 

5477.0

 

Share-based incentive compensation

 

 

(4.0

)

 

 

-

 

 

 

-

 

Foreign taxes

 

 

(0.2

)

 

 

(0.1

)

 

 

(361.6

)

State and local taxes

 

 

2.4

 

 

 

3.0

 

 

 

522.2

 

Income of non-controlling interests

 

 

(0.3

)

 

 

(0.3

)

 

 

13.8

 

Other, net

 

 

(0.2

)

 

 

(0.8

)

 

 

(31.5

)

Effective income tax rate (a)

 

 

68.5

%

 

 

23.9

%

 

 

6074.3

%

 

(a)

For the year ended December 31, 2015, the effective tax rate on “operating income (loss)” includes (i) the significant effect of the release of substantially all of our valuation allowance on deferred tax assets and the recognition of deferred tax assets associated with the recording of the tax receivable agreement obligation, as described below, and (ii) the negative impact on “operating income (loss)” as a result of the provision pursuant to the tax receivable agreement.

Schedule of Deferred Tax Assets and Liabilities

Details of the Company’s deferred tax assets and liabilities are as follows:

 

 

 

December 31,

 

 

 

2017

 

 

2016

 

Deferred Tax Assets:

 

 

 

 

 

 

 

 

Basis adjustments (a)

 

$

339,133

 

 

$

692,430

 

Compensation and benefits

 

 

175,456

 

 

 

197,750

 

Net operating loss and tax credit carryforwards

 

 

239,959

 

 

 

285,694

 

Depreciation and amortization

 

 

1,537

 

 

 

850

 

Other

 

 

34,615

 

 

 

53,895

 

Gross deferred tax assets

 

 

790,700

 

 

 

1,230,619

 

Valuation allowance

 

 

(61,456

)

 

 

(69,593

)

Deferred tax assets (net of valuation allowance)

 

 

729,244

 

 

 

1,161,026

 

Deferred Tax Liabilities:

 

 

 

 

 

 

 

 

Depreciation and amortization

 

 

17,257

 

 

 

26,539

 

Compensation and benefits

 

 

23,251

 

 

 

5,447

 

Goodwill

 

 

21,749

 

 

 

27,932

 

Other

 

 

26,134

 

 

 

34,499

 

Deferred tax liabilities

 

 

88,391

 

 

 

94,417

 

Net deferred tax assets

 

$

640,853

 

 

$

1,066,609

 

 

(a)

The basis adjustments recorded as of December 31, 2017 and 2016 are primarily the result of additional basis from acquisitions of interests, including the impact of the tax receivable agreement obligation.

Summary of Changes in Deferred Tax Assets Valuation Allowance

Changes in the deferred tax assets valuation allowance for the years ended December 31, 2017, 2016 and 2015 was as follows:

 

 

 

Year Ended December 31,

 

 

 

2017

 

 

2016

 

 

2015

 

Beginning Balance

 

$

69,593

 

 

$

89,251

 

 

$

1,044,152

 

Credited to provision (benefit) for income taxes

 

 

(23,670

)

 

 

(15,981

)

 

 

(954,487

)

Charged (credited) to other comprehensive income and

   other (a)

 

 

15,533

 

 

 

(3,677

)

 

 

(414

)

Ending Balance

 

$

61,456

 

 

$

69,593

 

 

$

89,251

 

 

(a)

In accordance with the new accounting guidance described above, 2017 includes recognition of previously unrecognized excess tax benefits offset by a valuation allowance of $12,090 recorded to retained earnings. 2016 includes acquisition-related deferred tax assets offset by a valuation allowance in the amount of $2,271.

Schedule of Gross Unrecognized Tax Benefits

A reconciliation of the beginning to the ending amount of gross unrecognized tax benefits (excluding interest and penalties) for the years ended December 31, 2017, 2016 and 2015 is as follows:

 

 

 

Year Ended December 31,

 

 

 

2017

 

 

2016

 

 

2015

 

Balance, January 1 (excluding interest and penalties

   of $15,392, $13,083 and $13,004, respectively)

 

$

78,396

 

 

$

77,280

 

 

$

68,224

 

Increases in gross unrecognized tax benefits relating

   to tax positions taken during:

 

 

 

 

 

 

 

 

 

 

 

 

Prior years

 

 

1,598

 

 

 

5,891

 

 

 

-

 

Current year

 

 

19,823

 

 

 

18,438

 

 

 

22,212

 

Decreases in gross unrecognized tax benefits

   relating to:

 

 

 

 

 

 

 

 

 

 

 

 

Tax positions taken during prior years

 

 

(2,961

)

 

 

(5,316

)

 

 

(621

)

Settlements with tax authorities

 

 

-

 

 

 

(1,706

)

 

 

-

 

Lapse of the applicable statute of limitations

 

 

(18,182

)

 

 

(16,191

)

 

 

(12,535

)

Balance, December 31 (excluding interest and

   penalties of $15,136, $15,392 and $13,083,

   respectively)

 

$

78,674

 

 

$

78,396

 

 

$

77,280

 

 

Schedule of Additional Information Relating to Unrecognized Tax Benefits

Additional information with respect to unrecognized tax benefits is as follows:

 

 

 

Year Ended December 31,

 

 

 

2017

 

 

2016

 

 

2015

 

Unrecognized tax benefits at the end of the year that,

   if recognized, would favorably affect the effective

   tax rate (includes interest and penalties of $15,136,

   $15,392 and $13,083, respectively)

 

$

78,841

 

 

$

81,564

 

 

$

74,785

 

Unrecognized tax benefits that, if recognized, would not

   affect the effective tax rate

 

$

14,969

 

 

$

12,224

 

 

$

15,578

 

Interest and penalties recognized in current income

   tax expense (after giving effect to the reversal of

   interest and penalties of $6,185, $3,143 and

   $3,865, respectively)

 

$

(256

)

 

$

2,309

 

 

$

79