14. TAXES ON EARNINGS

The Company accounts for income taxes under an asset and liability approach where deferred income taxes are based upon enacted tax laws and rates applicable to the periods in which the taxes become payable.

Taxes on earnings were as follows:

	Fiscal Years
	2014			2013			2012
(In millions)
Current provision:
Federal	$	86.6		$	110.1		$	99.3
State and local		6.1			13.4			8.5
Foreign		62.2			54.3			63.5
Total current		154.9			177.8			171.3
Deferred provision (benefit):
Federal		5.0			(3.9	)		(4.5	)
State and local		(0.1	)		(0.2	)		0.1
Foreign		11.0			0.1			2.0
Total deferred		15.9			(4.0	)		(2.4	)
Taxes on earnings	$	170.8		$	173.8		$	168.9

Earnings before taxes are generated from the following geographic areas:

	Fiscal Years
	2014		2013		2012
(In millions)
United States	$	173.9	$	308.0	$	271.4
Foreign		400.6		304.1		324.5
	$	574.5	$	612.1	$	595.9

The effective tax rate differs from the U.S. federal statutory tax rate as a result of the following:

	Fiscal Years
	2014				2013				2012

Federal statutory income tax rate		35.0		%		35.0		%		35.0		%
State and local taxes, net of federal tax benefit		0.8				1.3				1.3
Non-U.S. income taxed at different rates, net		(5.2	)			(5.6	)			(5.9	)
Resolution of tax contingencies due to lapses of statutes of limitations		(1.2	)			(1.2	)			(1.8	)
Other		0.3				(1.1	)			(0.3	)
Effective tax rate		29.7		%		28.4		%		28.3		%

During fiscal years 2014, 2013 and 2012, the Company’s effective tax rate was lower than the U.S. federal statutory rate primarily because the Company’s foreign earnings are taxed at rates that, on average, are lower than the U.S. federal rate. This reduction is partly offset by the fact that the Company’s domestic earnings are also subject to state income taxes. During fiscal years 2014, 2013 and 2012, the benefit of the release of liabilities for uncertain tax positions as a result of the expiration of the statutes of limitation in various jurisdictions also contributed to the Company’s effective tax rate being lower than the U.S. federal statutory rate.

Significant components of deferred tax assets and liabilities are as follows:

	September 26,			September 27,
(In millions)	2014			2013
Deferred Tax Assets:
Deferred revenues	$	26.9		$	26.8
Deferred compensation		37.3			34.9
Product warranty		10.9			13.9
Inventory adjustments		19.7			18.3
Equity-based compensation		28.8			33.3
Environmental reserve		4.8			5.7
Accruals and reserves		14.3			12.1
Net operating loss carryforwards		79.1			78.6
Other		38.2			25.7
		260.0			249.3
Valuation allowance		(67.5	)		(60.7	)
Total deferred tax assets		192.5			188.6
Deferred Tax Liabilities:
Tax-deductible goodwill		(27.7	)		(27.3	)
Fixed assets		(16.3	)		(17.7	)
Unremitted earnings of foreign subsidiaries		(24.0	)		(9.4	)
Other		(29.3	)		(21.0	)
Total deferred tax liabilities		(97.3	)		(75.4	)
Net deferred tax assets	$	95.2		$	113.2
Reported As:
Net current deferred tax assets	$	126.0		$	122.3
Net long-term deferred tax assets (included in other assets)		11.5			10.5
Net current deferred tax liabilities (included in accrued expenses)		(10.8	)		(7.6	)
Net long-term deferred tax liabilities (included in other long-term liabilities)		(31.5	)		(12.0	)
Net deferred tax assets	$	95.2		$	113.2

The Company has not provided for U.S. federal income and foreign withholding taxes on $1,537.6 million of cumulative undistributed earnings of non-U.S. subsidiaries as of September 26, 2014. Such earnings are intended to be reinvested in the non-U.S. subsidiaries for an indefinite period of time. If such earnings were not considered to be reinvested indefinitely, an additional deferred taxes liability of approximately $381.0 million would be provided.

The Company has federal net operating loss carryforwards of approximately $13.4 million expiring between 2018 and 2031. The federal net operating loss carryforwards are subject to an annual limitation of approximately $1.3 million per year. The Company has state net operating loss carryforwards of $13.4 million expiring between 2018 and 2032. The Company has foreign net operating loss carryforwards of $226.0 million with an indefinite life. Of this amount, $22.6 million is unavailable to the Company under local loss utilization rules.

The valuation allowance relates primarily to net operating losses in certain foreign jurisdictions where, based on the weight of available evidence, it is more likely than not that the tax benefit of the net operating losses will not be realized. The valuation allowance increased by $6.8 million during fiscal year 2014, increased by $14.9 million during fiscal year 2013, and decreased by $1.1 million in fiscal year 2012.

Income taxes paid were as follows:

	Fiscal Years
	2014		2013		2012
(In millions)
Federal income taxes paid, net	$	66.2	$	119.1	$	77.6
State, income taxes paid, net		7.3		14.9		9.3
Foreign income taxes paid, net		67.3		69.4		47.7
Total income taxes paid, net	$	140.8	$	203.4	$	134.6

The Company accounts for uncertainty in income taxes following a two-step approach for recognizing and measuring uncertain tax positions. The first step is to evaluate the tax position for recognition by determining whether the weight of available evidence indicates that it is more likely than not that, based on the technical merits, the position will be sustained on audit, including resolution of related appeals or litigation processes, if any. The second step is to measure the tax benefit as the largest amount that is more than 50% likely of being realized upon settlement.

Changes in the Company’s unrecognized tax benefits were as follows:

	Fiscal Years
	2014			2013			2012
(In millions)
Unrecognized tax benefits balance–beginning of fiscal year	$	37.0		$	38.8		$	37.1
Additions based on tax positions related to a prior year		10.7			2.5			3.8
Reductions based on tax positions related to a prior year		(0.3	)		(0.7	)		(0.9	)
Additions based on tax positions related to the current year		8.2			6.6			6.8
Settlements		(0.4	)		(4.2	)		(0.4	)
Reductions resulting from the expiration of the applicable statute of limitations		(5.6	)		(6.0	)		(7.6	)
Unrecognized tax benefits balance–end of fiscal year	$	49.6		$	37.0		$	38.8

As of September 26, 2014, the total amount of gross unrecognized tax benefits was $49.6 million. Of this amount, $32.2 million would affect the effective tax rate if recognized. The difference would be offset by changes to deferred tax assets and liabilities.

The Company includes interest and penalties related to income taxes within taxes on earnings on the Consolidated Statements of Earnings. As of September 26, 2014, the Company had accrued $7.8 million for the payment of interest and penalties related to unrecognized tax benefits. During fiscal year 2014, a net expense of $1.1 million related to interest and penalties was included in taxes on earnings. As of September 27, 2013, the Company had accrued $6.7 million for the payment of interest and penalties related to unrecognized tax benefits. During fiscal year 2013, a net benefit of $1.2 million related to interest and penalties was included in taxes on earnings.

The Company files U.S. federal, U.S. state, and foreign tax returns. The Company’s U.S. federal tax returns are generally no longer subject to tax examinations for years prior to 2011. The Company has significant operations in Switzerland. The Company’s Swiss tax returns are generally no longer subject to tax examinations for years prior to 2010. For U.S. states and other foreign tax returns, the Company is generally no longer subject to tax examinations for years prior to 2007.