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Income Taxes
6 Months Ended
Jun. 30, 2017
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,
 
2017
 
2016
 
2017
 
2016
 
in millions
 
 
 
 
 
 
 
 
Computed “expected” tax benefit (expense) (a)
$
100.6

 
$
(33.0
)
 
$
123.8

 
$
51.3

Change in valuation allowances (b):
 
 
 
 
 
 
 
Expense
(125.8
)
 
(1.5
)
 
(207.7
)
 
(235.1
)
Benefit
11.6

 
(119.8
)
 
35.4

 
13.9

Non-deductible or non-taxable foreign currency exchange results (b):
 
 
 
 
 
 
 
Expense
(116.1
)
 
(1.0
)
 
(174.6
)
 
(2.3
)
Benefit
2.4

 
103.5

 
4.3

 
122.1

Non-deductible or non-taxable interest and other items (b):
 
 
 
 
 
 
 
Expense
(29.5
)
 
(23.1
)
 
(99.2
)
 
(45.2
)
Benefit
10.9

 
12.0

 
24.0

 
21.9

International rate differences (b) (c):
 
 
 
 
 
 
 
Benefit
43.2

 
41.8

 
79.0

 
77.0

Expense
(14.9
)
 
(16.4
)
 
(46.6
)
 
(23.0
)
Basis and other differences in the treatment of items associated with investments in subsidiaries and affiliates (b):
 
 
 
 
 
 
 
Expense
(14.0
)
 
(73.4
)
 
(28.0
)
 
(97.1
)
Benefit
2.2

 
7.5

 
2.6

 
18.8

Enacted tax law and rate change
6.7

 
(1.0
)
 
16.4

 
(5.2
)
Recognition of previously unrecognized tax benefits
5.3

 
2.9

 
8.9

 
17.9

Tax effect of intercompany financing

 
47.0

 

 
85.1

Other, net
(12.3
)
 
(1.5
)
 
(14.8
)
 
(7.2
)
Total income tax expense
$
(129.7
)
 
$
(56.0
)
 
$
(276.5
)
 
$
(7.1
)
_______________

(a)
The statutory or “expected” tax rates are U.K. rates of 19.25% for the 2017 periods and 20.0% for the 2016 periods. The statutory rate for the 2017 periods represents the blended rate that will be in effect for the year ended December 31, 2017 based on the 20.0% statutory rate that was in effect for the first quarter of 2017 and the 19.0% statutory rate that is in effect for the remainder of 2017.

(b)
Country jurisdictions giving rise to income tax benefits are grouped together and shown separately from country jurisdictions giving rise to income tax expenses.

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

At June 30, 2017, our unrecognized tax benefits of $566.1 million included $508.7 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.

During the next 12 months, it is reasonably possible that the resolution of ongoing examinations by tax authorities, as well as the expiration of statutes of limitation, could result in reductions to our unrecognized tax benefits related to tax positions taken as of June 30, 2017. 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.

We are currently undergoing income tax audits in Austria, Chile, Germany, the Netherlands, Panama, Poland, Trinidad and Tobago, the U.S. and certain other jurisdictions within Latin America and the Caribbean. 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 2009 and 2010 income tax returns, and have entered into the appeals process with respect to the 2009 and 2010 matters. In Chile, adjustments received from the tax authorities for the tax years 2011 and 2012 are in dispute. We have appealed these adjustments to the Chilean tax court. Also in Chile, we recorded an income tax receivable in connection with the expected utilization of certain net operating loss carryforwards upon the completion of a merger transaction of two indirect subsidiaries of Liberty Global. We are engaged in an ongoing examination by tax authorities in Chile in connection with this receivable and were notified during the third quarter of 2016 that approximately 48% of our claim has been agreed by the tax authorities. This refund was received during the second quarter of 2017. We intend to pursue the payment of the remaining portion of this receivable through all available methods. 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.