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Income Taxes
6 Months Ended
Jun. 30, 2015
Accrued Income Taxes [Abstract]  
Income Taxes
 Income Taxes

Income tax benefit (expense) attributable to our loss from continuing operations before income taxes differs from the amounts computed using the applicable income tax rate as a result of the following factors:
 
Three months ended
 
Six months ended
 
June 30,
 
June 30,
 
2015
 
2014
 
2015
 
2014
 
in millions
 
 
 
 
 
 
 
 
Computed “expected” tax benefit (a)
$
56.0

 
$
49.3

 
$
175.9

 
$
162.0

Change in valuation allowances (b):
 
 
 
 
 
 
 
Decrease
(160.3
)
 
(193.5
)
 
(386.3
)
 
(248.7
)
Increase
42.8

 
101.3

 
43.8

 
106.2

International rate differences (b) (c):
 
 
 
 
 
 
 
Increase
31.4

 
57.0

 
125.3

 
116.5

Decrease
(21.0
)
 
(8.3
)
 
(34.5
)
 
(13.8
)
Tax effect of intercompany financing
38.5

 
41.0

 
76.7

 
81.5

Non-deductible or non-taxable foreign currency exchange results (b):
 
 
 
 
 
 
 
Decrease
(21.2
)
 
(16.5
)
 
(29.9
)
 
(23.9
)
Increase
(67.3
)
 
(1.5
)
 
2.2

 
0.6

Non-deductible or non-taxable interest and other expenses (b):
 
 
 
 
 
 
 
Decrease
(15.3
)
 
(53.2
)
 
(49.0
)
 
(84.2
)
Increase
12.1

 
16.1

 
23.3

 
31.1

Basis and other differences in the treatment of items associated with investments in subsidiaries and affiliates (b):
 
 
 
 
 
 
 
Decrease
(26.7
)
 
3.7

 
(27.7
)
 
(45.9
)
Increase
(2.7
)
 
3.8

 
11.8

 
4.3

Recognition of previously unrecognized tax benefits
4.7

 

 
13.6

 
28.8

Tax benefit associated with technology innovation
6.6

 

 
10.5

 

Other, net
(7.6
)
 
1.4

 
(7.8
)
 
3.1

Total income tax benefit (expense)
$
(130.0
)
 
$
0.6

 
$
(52.1
)
 
$
117.6

_______________

(a)
The statutory or “expected” tax rates are the U.K. rates of 20.0% for the 2015 periods and 21.0% for 2014 periods.

(b)
Country jurisdictions giving rise to increases within the six-month period are grouped together and shown separately from country jurisdictions giving rise to decreases within the six-month period.

(c)
Amounts reflect adjustments (either an increase or a decrease) to “expected” tax benefit for statutory rates in jurisdictions in which we operate outside of the U.K.

As of June 30, 2015, our unrecognized tax benefits of $561.6 million included $284.5 million of tax benefits that would have a favorable impact on our effective income tax rate if ultimately recognized, after considering amounts that we would expect to be offset by valuation allowances.

We are currently undergoing income tax audits in Czech Republic, Chile, Germany, the Netherlands, Slovakia, Switzerland and the U.S. In the U.S., the consolidated income tax returns of Liberty Global, Inc. (LGI) for 2009 through 2015 are under examination. We have received notices of adjustment from the Internal Revenue Service with respect to our 2013, 2010 and 2009 taxable income and we have entered into the appeals process with respect to the 2010 and 2009 matters. While we believe that the ultimate resolution of these proposed adjustments will not have a material impact on our consolidated financial position, results of operations or cash flows, no assurance can be given that this will be the case given the amounts involved and the complex nature of the related issues. During the next 12 months, it is reasonably possible that the resolution of ongoing examinations by tax authorities as well as expiration of statutes of limitation could result in significant reductions to our unrecognized tax benefits related to tax positions taken as of June 30, 2015. The amount of any such reductions could range up to $250 million. Other than the potential impacts of these ongoing examinations and the expected expiration of certain statutes of limitation, we do not expect any material changes to our unrecognized tax benefits during the next 12 months. No assurance can be given as to the nature or impact of any changes in our unrecognized tax positions during the next 12 months.