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Income Taxes
12 Months Ended
Dec. 31, 2019
Income Tax Disclosure [Abstract]  
Income Taxes
Note 11: Income Taxes
The significant components of income/(loss) before income taxes and the income tax provision/(benefit) from continuing operations are as follows (in millions):
 
 
Year Ended
December 31, 2019
 
Year Ended
December 31, 2018
 
Year Ended
December 31, 2017
 
United States
 
$
(38.6
)
 
$
(65.6
)
 
$
(231.4
)
 
Other countries
 
81.4

 
(145.2
)
 
(110.4
)
 
Income/(loss) before income tax
 
$
42.8

 
$
(210.8
)
 
$
(341.8
)
 
 
 
Year Ended
December 31, 2019
 
Year Ended
December 31, 2018
 
Year Ended
December 31, 2017
 
United States federal:
 
 
 
 
 
 
 
Current
 
$
17.4

 
$
(3.2
)
 
$
1.4

 
Deferred
 
(14.6
)
 
(47.8
)
 
(180.4
)
 
Total United States federal income taxes
 
2.8

 
(51.0
)
 
(179.0
)
 
United States state and local:
 
 
 
 
 
 
 
Current
 
13.4

 
(0.2
)
 
17.1

 
Deferred
 
(19.5
)
 
(1.1
)
 
4.6

 
Total United States state and local income taxes
 
(6.1
)
 
(1.3
)
 
21.7

 
All other countries:
 
 
 
 
 
 
 
Current
 
57.9

 
37.1

 
44.4

 
Deferred
 
(12.0
)
 
(9.8
)
 
(7.6
)
 
Total all other countries income taxes
 
45.9

 
27.3

 
36.8

 
Total income tax provision/(benefit)
 
$
42.6

 
$
(25.0
)
 
$
(120.5
)
 

Differences between income tax expense reported for financial reporting purposes and tax expense computed based upon the application of the United States federal tax rate to the reported income/(loss) before income taxes are as follows (in millions):
 
 
Year Ended
December 31, 2019
 
Year Ended
December 31, 2018
 
Year Ended
December 31, 2017
 
Reconciliation of effective tax rate
 
 
 
 
 
 
 
Income/(loss) before income taxes
 
$
42.8

 
$
(210.8
)
 
$
(341.8
)
 
Taxes at the statutory rate
 
9.0

 
(44.9
)
 
(119.7
)
 
Adjusted for:
 
 
 
 
 
 
 
State taxes, net of the federal benefit
 
(2.9
)
 
(1.2
)
 
8.7

 
Other permanent adjustments
 
19.3

 
11.3

 
(5.3
)
 
Foreign tax rate differential
 
0.3

 
0.5

 
13.3

 
Change in valuation allowance
 
(9.7
)
 
41.1

 
30.5

 
Impact of repatriation
 
12.0

 
(0.7
)
 
7.7

 
Uncertain tax positions
 
4.3

 
0.7

 
11.3

 
Transfer pricing
 

 

 
(13.1
)
 
Deferred tax inventory
 
4.5

 

 

 
Impact of restructuring
 
6.0

 

 

 
Other, net
 
(0.2
)
 
(2.6
)
 
7.0

 
Impact of US tax reform
 


(29.2
)
 
(60.9
)
 
Income tax expense/(benefit)
 
$
42.6

 
$
(25.0
)
 
$
(120.5
)
 

The tax effect of temporary differences that gave rise to deferred tax assets and liabilities are as follows (in millions):
 
 
As of
December 31, 2019
 
As of
December 31, 2018
Deferred tax assets
 
 
 
 
Liabilities
 
$
204.0

 
$
107.8

Deferred expenditures
 
78.9

 
73.6

Employee benefits
 
82.4

 
45.5

Tax losses / credits
 
152.7

 
199.2

Intangible assets
 
17.7

 
18.5

Other
 
3.7

 
10.8

 
 
539.4

 
455.4

Less: valuation allowance
 
(183.5
)
 
(206.6
)
Total deferred tax assets
 
$
355.9

 
$
248.8

 
 
 
 
 
Deferred tax liabilities
 
 
 
 
Property, plant and equipment
 
$
(14.7
)
 
$
(25.2
)
Intangible assets
 
(253.5
)
 
(259.7
)
Income recognition
 
(14.4
)
 
(16.3
)
Right-of-use asset
 
(96.7
)
 

Total deferred tax liabilities
 
(379.3
)
 
(301.2
)
Total net deferred tax liabilities
 
$
(23.4
)
 
$
(52.4
)

The Company had total valuation allowances of $183.5 million and $206.6 million at December 31, 2019 and 2018, respectively, as it was determined that it was more likely than not that certain deferred tax assets would not be realized. These valuation allowances relate to tax loss carryforwards, other tax attributes and temporary differences that are available to reduce future tax liabilities.
The total amount of gross unrecognized tax benefits was $26.9 million and $23.5 million at December 31, 2019 and 2018, respectively. It is reasonably possible that unrecognized tax benefits could change by approximately $4.4 million during the next twelve months. Accrued interest and penalties related to uncertain tax positions are included in the tax provision. The Company accrued interest and penalties of $8.6 million and $10.1 million as of December 31, 2019 and 2018, respectively, net of federal and state income tax benefits as applicable. The provision for income taxes includes expense for interest and penalties (release of interest and penalties) of $(1.5) million, $1.2 million and $2.5 million in 2019, 2018 and 2017 respectively, net of federal and state income tax benefits as applicable.
Changes in the Company’s unrecognized tax benefits are (in millions):
 
 
Year Ended December 31, 2019
 
Year Ended December 31, 2018
 
Year Ended December 31, 2017
Beginning of year
 
$
23.5

 
$
26.3

 
$
21.1

Increases from prior period tax positions

 
5.4

 
1.3

 
7.6

Decreases from prior period tax positions
 
(0.8
)
 
(3.0
)
 
(0.7
)
Increases from current period tax positions
 
4.7

 
0.2

 
4.4

Decreases relating to settlements with taxing authorities
 
(5.9
)
 
(1.3
)
 
(6.1
)
End of year
 
$
26.9

 
$
23.5

 
$
26.3


The Company is subject to income taxation in various U.S. states and foreign jurisdictions. Generally, the Company’s open tax years include those from 2006 to the present, although audits by taxing authorities for more recent years have been completed or are in process in several jurisdictions. As of December 31, 2019, the Company is under examination in the U.S., Singapore, and India.
As of December 31, 2019, and 2018, the Company has accumulated $6.5 billion and $2.8 billion of undistributed earnings. These earnings do not meet the indefinite reinvestment criteria because the Company does not intend to
permanently reinvest such earnings. The deferred tax liability of $16.9 million as of December 31, 2019 relates to income taxes and withholding taxes on potential future distributions of cash balances in excess of working capital requirements.
As of December 31, 2019, and 2018, the Company had available operating loss carryforwards of $149.5 million and $191.0 million, respectively, which will begin to expire in 2020, and foreign tax credit carryforwards of $4.0 million and $8.2 million, respectively. The Company also had a U.S. interest expense disallowance carryforward of $76.8 million and $54.1 million as of December 31, 2019 and 2018, respectively, which has an indefinite carryforward.
The change in deferred tax balances for operating loss carryovers from 2018 to 2019 includes increases from current year losses and decreases from current year utilization. The jurisdictional location of the operating loss carryforward is broken out as follows:
 
 
As of
December 31, 2019
 
Range of expiration dates
United States
 
$
23.0

 
2020 - Indefinite
All other countries
 
126.5

 
2020 - Indefinite
Total
 
$
149.5

 
 

Valuation allowances have been provided regarding the tax benefit of certain net operating loss, interest expense disallowance, and tax credit carryforwards, for which it has been concluded that it is more likely than not that the deferred tax asset will not be realized. Management assesses the positive and negative evidence to estimate whether sufficient future taxable income will be generated to permit use of the existing deferred tax assets. A significant piece of objective negative evidence evaluated was the cumulative loss incurred over a three-year period ended December 31, 2019. Such objective evidence limits the ability to consider other subjective evidence, such as the Company's projections for future growth. Valuation allowances were decreased in 2019 by $23.1 million overall, primarily due to the expected future utilization and current year consumption of the tax attributes.