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Income Taxes
6 Months Ended
Jun. 30, 2019
Income Taxes  
Income Taxes

13. Income Taxes

The Company’s provision for income taxes for the three and six months ended June 30, 2019 and 2018 is based on the estimated annual effective tax rate, in addition to discrete items. The Company’s effective tax rates on pre-tax income were 17.5% and 14.8% for the three months ended June 30, 2019 and 2018, respectively, and 18.1% and 12.0% for the six months ended June 30, 2019 and 2018. The increase in the Company’s effective tax rate for both the three and six months ended June 30, 2019 compared to the prior periods was primarily due to discrete tax benefits recognized in the prior periods and an increase in 2019 domestic pre-tax income due to the net gain on the sales of the Speedpay and Paymap businesses. The discrete benefits in the prior year periods included adjustments to the Company's accounting for the implementation of the Tax Act during the first half of 2018 which reduced the Company’s effective tax rate by 2.5 percentage points for both the three and six months ended June 30, 2018, as certain of the Tax Act’s impacts had been provisionally estimated during the prior period. The Company currently expects that approximately 67% of the Company’s pre-tax income will be derived from foreign sources for the year ending December 31, 2019. Certain portions of the Company’s foreign source income are subject to United States federal and state income tax as earned due to the nature of the income.

Uncertain Tax Positions

The Company has established contingency reserves for a variety of material, known tax exposures. The Company’s tax reserves reflect management’s judgment as to the resolution of the issues involved if subject to judicial review or other settlement. While the Company believes its reserves are adequate to cover reasonably expected tax risks, there can be no assurance that, in all instances, an issue raised by a tax authority will be resolved at a financial cost that does not exceed its related reserve. With respect to these reserves, the Company’s income tax expense would include (i) any changes in tax reserves arising from material changes during the period in the facts and circumstances (i.e., new information) surrounding a tax issue and (ii) any difference from the Company’s tax position as recorded in the financial statements and the final resolution of a tax issue during the period. Such resolution could materially increase or decrease income tax expense in the Company’s consolidated financial statements in future periods and could impact operating cash flows.

Unrecognized tax benefits represent the aggregate tax effect of differences between tax return positions and the amounts otherwise recognized in the Company’s consolidated financial statements, and are reflected in "Income taxes payable" in the Condensed Consolidated Balance Sheets. The total amount of unrecognized tax benefits as of June 30, 2019 and December 31, 2018 was $298.8 million and $295.0 million, respectively, excluding interest and penalties. The total amount of unrecognized tax benefits that, if recognized, would affect the effective tax rate was $286.6 million and $284.2 million as of June 30, 2019 and December 31, 2018, respectively, excluding interest and penalties.

The Company recognizes interest and penalties with respect to unrecognized tax benefits in "Provision for income taxes" in its Condensed Consolidated Statements of Income, and records the associated liability in "Income taxes payable" in its Condensed Consolidated Balance Sheets. The Company recognized immaterial amounts of interest and penalties during the three and six months ended June 30, 2019 and 2018, respectively. The Company has accrued $27.3 million and $23.9 million for the payment of interest and penalties as of June 30, 2019 and December 31, 2018, respectively.

The Company and its subsidiaries file tax returns for the United States, for multiple states and localities, and for various non-United States jurisdictions, and the Company has identified the United States as its major tax jurisdiction, as the income tax imposed by any one foreign country is not material to the Company. The Company’s United States federal income tax returns since 2015 are eligible to be examined.