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INCOME TAXES
9 Months Ended
Sep. 30, 2016
Income Tax Disclosure [Abstract]  
INCOME TAXES
    INCOME TAXES
 
The Company’s effective tax rate (“ETR”) differs from the statutory tax rate predominantly due to the favorable impact of tax rulings and agreements in various foreign jurisdictions. The Company and the Dutch tax authorities previously agreed to the appropriate remuneration attributable to Dutch manufacturing activities through the year ending December 31, 2019. In addition, the Company negotiated a tax ruling effective from January 1, 2013, under which certain profits in Singapore are eligible for favorable taxation through the year ending December 31, 2027.

For the three and nine months ended September 30, 2016, the ETR was 26.4% and 25.8%, respectively, compared with 26.8% and 24.9% for the same periods in 2015. The ETR decrease for the three months ended September 30, 2016 was driven 6.5% by tax credits from the repatriation of foreign earnings to the United States, offset almost entirely by a change in valuation allowances associated with the Company’s Brazilian and Indonesian subsidiaries. The ETR increase for the nine months ended September 30, 2016 was driven 4.0% by the Company’s Venezuelan subsidiary which incurred a remeasurement loss on its monetary assets and an impairment charge on its long-lived assets in 2016 (both of which provided no tax benefit - see Note 18 for additional information) and approximately 3% due to the establishment of a valuation allowance associated with the Company’s Brazilian subsidiary, offset 6.0% by tax credits from the repatriation of foreign earnings to the United States.

The Company’s gross reserve for uncertain tax positions including penalties and interest, as of September 30, 2016 and December 31, 2015, was $193.4 million and $167.0 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 its two largest businesses in the United States and China. It is reasonably possible that new issues may be raised by tax authorities and that these issues may require increases in the balance of the reserve for uncertain tax positions. 

With respect to the United States examination, the Company is discussing various transfer pricing matters with the Internal Revenue Service as part of its routine audit. Within the next twelve months, it is reasonably possible that the Company’s reserve for uncertain tax positions could change following the closure of the audit. An estimate of the change cannot be made as of September 30, 2016.