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INCOME TAXES
9 Months Ended
Sep. 30, 2014
Income Tax Disclosure [Abstract]  
INCOME TAXES
    INCOME TAXES
 
For the three months ended September 30, 2014, the effective tax rate (“ETR”) was 16.0% compared with 28.8% for the same period in 2013. This decrease was primarily due to a change in the reserve for uncertain tax positions, the majority of which relates to the running of the statute of limitations in various jurisdictions during the third quarter of 2014, and the third quarter 2013 administrative penalty in China which was non-deductible for tax purposes.

For the nine months ended September 30, 2014, the ETR was 21.9% compared with 27.2% for the same period in 2013. This decrease was primarily due to the running of the statute of limitations as noted above, favorable geographic earnings mix, and the non-deductible third quarter 2013 administrative penalty in China.


The Company’s gross reserve for uncertain tax positions, including penalties and interest, as of September 30, 2014 and December 31, 2013, was $137.2 million and $117.4 million, respectively. The Company believes that it has adequately provided for all uncertain tax positions. The Company is currently under examination by taxing authorities in various jurisdictions in which it operates, including the United States. It is reasonably possible that new issues may be raised by tax authorities and that these issues may require adjustments to the balance of uncertain tax positions. 
 
Pursuant to the Amended and Restated Tax Matters Agreement dated December 18, 2009, Bristol-Myers Squibb Company (“BMS”), the Company’s former parent, maintains responsibility for all uncertain tax positions which may exist in the pre-initial public offering period or which may exist as a result of the initial public offering transaction. The Company has a receivable from BMS for uncertain tax positions, including penalties and interest, of $9.5 million and $8.9 million as of September 30, 2014 and December 31, 2013 respectively.