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Income Taxes
 6 Months Ended
Jun. 30, 2016
Accrued Income Taxes [Abstract]  
Income Taxes
 Income Taxes

Income tax expense attributable to our earnings (loss) 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,
 
2016
 
2015
 
2016
 
2015
 
in millions
 
 
 
 
 
 
 
 
Computed “expected” tax benefit (expense) (a)
$
(33.0
)
 
$
56.0

 
$
51.3

 
$
175.9

Change in valuation allowances (b):
 
 
 
 
 
 
 
Decrease
(1.5
)
 
(160.3
)
 
(235.1
)
 
(386.3
)
Increase
(119.8
)
 
42.8

 
13.9

 
43.8

Non-deductible or non-taxable foreign currency exchange results (b):
 
 
 
 
 
 
 
Increase
103.5

 
(67.3
)
 
122.1

 
2.2

Decrease
(1.0
)
 
(21.2
)
 
(2.3
)
 
(29.9
)
Tax effect of intercompany financing
47.0

 
38.5

 
85.1

 
76.7

Basis and other differences in the treatment of items associated with investments in subsidiaries and affiliates (b):
 
 
 
 
 
 
 
Decrease
(74.7
)
 
(26.7
)
 
(98.4
)
 
(27.7
)
Increase
7.5

 
(2.7
)
 
18.8

 
11.8

International rate differences (b) (c):
 
 
 
 
 
 
 
Increase
41.8

 
31.4

 
77.0

 
125.3

Decrease
(16.4
)
 
(21.0
)
 
(23.0
)
 
(34.5
)
Non-deductible or non-taxable interest and other expenses (b):
 
 
 
 
 
 
 
Decrease
(23.1
)
 
(15.3
)
 
(45.2
)
 
(49.0
)
Increase
12.0

 
12.1

 
21.9

 
23.3

Recognition of previously unrecognized tax benefits
2.9

 
4.7

 
17.9

 
13.6

Other, net
(1.2
)
 
(1.0
)
 
(11.1
)
 
2.7

Total income tax expense
$
(56.0
)
 
$
(130.0
)
 
$
(7.1
)
 
$
(52.1
)
_______________

(a)
The statutory or “expected” tax rate is the U.K. rate of 20.0%. During 2015, the U.K. enacted legislation that will change the corporate income tax rate from the current rate of 20.0% to 19.0% in April 2017 and 18.0% in April 2020. Substantially all of the impact of these rate changes on our deferred tax balances was recorded in the fourth quarter of 2015 when the change in law was enacted.

(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 (expense) for statutory rates in jurisdictions in which we operate outside of the U.K.

At June 30, 2016, our unrecognized tax benefits of $729.7 million included $364.5 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 and other factors.

We are currently undergoing income tax audits in Chile, the Czech Republic, Germany, Hungary, the Netherlands, Panama, Poland, Slovakia, Switzerland, Trinidad & Tobago, the U.S. and certain other jurisdictions within the Caribbean and Latin America. Except as noted below, any adjustments that might arise from the foregoing examinations are not expected to have a material impact on our consolidated financial position or results of operations. In the U.S., we have received notices of adjustment from the Internal Revenue Service with respect to our 2010 and 2009 income tax returns, as well as a proposed adjustment to our 2013 withholding tax return. We have entered into the appeals process with respect to the 2013, 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, 2016. 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.