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Income Taxes
 9 Months Ended
Sep. 30, 2020
Accrued Income Taxes [Abstract]  
Income Taxes Income Taxes

Income tax benefit attributable to our earnings (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
September 30,
 
Nine months ended
September 30,
 
2020
 
2019
 
2020
 
2019
 
in millions
 
 
 
 
 
 
 
 
Computed “expected” tax benefit (expense) (a)
$
215.6

 
$
(98.2
)
 
$
132.8

 
$
14.3

Enacted tax law and rate changes (b)
242.3

 
12.1

 
274.0

 
2.3

Change in valuation allowances
(98.7
)
 
132.8

 
(198.3
)
 
199.2

Recognition of previously unrecognized tax benefits
—

 
(3.5
)
 
188.8

 
0.9

Non-deductible or non-taxable foreign currency exchange results
(224.4
)
 
102.7

 
(166.6
)
 
152.1

Tax benefit associated with technology innovation (c)
4.9

 
—

 
54.4

 


Basis and other differences in the treatment of items associated with investments in subsidiaries and affiliates (d)
(8.6
)
 
(49.8
)
 
(26.3
)
 
(216.2
)
Non-deductible or non-taxable interest and other items
26.2

 
(22.3
)
 
(20.1
)
 
(152.2
)
International rate differences (e)
(2.9
)
 
(2.1
)
 
(6.7
)
 
13.4

Other, net
6.8

 
(0.9
)
 
7.1

 
2.4

Total income tax benefit
$
161.2

 
$
70.8

 
$
239.1

 
$
16.2

_______________

(a)
The statutory or “expected” tax rate is the U.K. rate of 19.0%.

(b)
On July 22, 2020, legislation was enacted in the U.K. to maintain the corporate income tax rate at 19.0%, reversing previous legislation that had reduced the U.K. rate to 17.0% from April 1, 2020. The impact of this rate change on our deferred balances was recorded during the third quarter of 2020.

(c)
Amount reflects the recognition of the innovation income tax deduction in Belgium, including the one-time effect of deductions related to prior periods.

(d)
These amounts reflect the net impact of differences in the treatment of income and loss items between financial reporting and tax accounting related to investments in subsidiaries and affiliates including the effects of foreign earnings.

(e)
Amounts reflect adjustments (either a benefit or expense) to the “expected” tax benefit (expense) for statutory rates in jurisdictions in which we operate outside of the U.K.
 
As of September 30, 2020, our unrecognized tax benefits of $340.0 million included $145.9 million of unrecognized 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 and other items, could result in reductions to our unrecognized tax benefits related to tax positions taken as of September 30, 2020. The amount of any such reductions could range up to $55.0 million, of which approximately $5.0 million would have a positive impact on our effective tax rate. 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.

Certain of our subsidiaries are currently involved in income tax examinations in various jurisdictions in which we operate, including the Netherlands, Poland, the U.K. and the U.S. While we do not expect adjustments from the foregoing examinations to 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.