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Income Taxes
12 Months Ended
Dec. 31, 2020
Income Tax Disclosure [Abstract]  
Income Taxes
INCOME TAXES
For each of the years ended December 31, 2020, 2019, and 2018 the tax data related to continuing operations is as follows:
202020192018
Income components:
United States$(124.3)$143.9 $114.4 
International209.5 270.5 276.6 
Income from continuing operations before income tax85.2 414.4 391.0 
Income tax expense components:
Current income tax expense:
United States – federal9.9 9.4 6.3 
United States – state and local(1.5)0.5 7.9 
International50.8 49.1 58.2 
Total current income tax expense59.2 59.0 72.4 
Deferred income tax (benefit) expense components:
United States – federal(36.6)10.1 7.4 
United States – state and local(4.8)1.5 (0.2)
International(2.5)19.3 (21.9)
Total deferred income tax (benefit) expense (43.9)30.9 (14.7)
Income tax expense$15.3 $89.9 $57.7 
Effective income tax rate18.0 %21.7 %14.8 %
A reconciliation of the income tax expense for continuing operations from the U.S. statutory income tax rate to the effective income tax rate is as follows for each of the years ended December 31, 2020, 2019, and 2018:
202020192018
Tax provision at U.S. statutory rate21.0 %21.0 %21.0 %
Tax on undistributed foreign earnings7.4 %1.8 %(1.2)%
Pension settlement AOCI expense5.9 %— %— %
Italy patent box (5.6)%(1.2)%(1.0)%
Audit settlements and unrecognized tax benefits(5.4)%0.1 %(0.3)%
Excess tax benefits on stock-based compensation(3.6)%(1.1)%(0.6)%
State and local income tax(2.4)%0.7 %1.5 %
Foreign tax rate differential1.6 %2.8 %3.7 %
Valuation allowance on deferred tax assets1.5 %(0.5)%(2.4)%
U.S. tax on foreign earnings(0.2)%— %0.5 %
U.S. permanent items(0.1)%(1.0)%0.4 %
Tax exempt interest %— %(5.8)%
One-time tax on foreign earnings - Tax Act %— %(1.0)%
Federal deferred taxes remeasurement - Tax Act %— %0.4 %
Other adjustments(2.1)%(0.9)%(0.4)%
Effective income tax rate18.0 %21.7 %14.8 %
The decrease in the effective tax rate in 2020 compared to 2019 was due to a benefit of $25.9 resulting from a recently completed internal reorganization in Europe. The reorganization increased projections of future earnings, which will result in the realization of a portion of our deferred tax assets. This benefit was partially offset by the recognition of a $21.7 valuation allowance on our Germany and UK entities. The effective tax rate in 2019 compared to 2018 was higher primarily due to tax benefits of $22.9 in 2018 from valuation allowance reversals on deferred tax assets. At the end of 2018, ITT capitalized its investment in a foreign subsidiary, which eliminated its tax exempt interest.
The Company’s financial condition and results of operations have been and may continue to be adversely affected by the COVID-19 pandemic and the governmental and market reactions to COVID-19. The impacts on earnings have already had, and may continue to have, an impact on the Company’s overall effective tax rate.
The Coronavirus Aid, Relief, and Economic Security Act (the CARES Act) was enacted March 27, 2020. The CARES Act provides numerous tax provisions and other stimulus measures, including temporary changes regarding the prior and future utilization of net operating losses, temporary suspension of certain payment requirements for the employer portion of Social Security taxes, and the creation of certain refundable employee retention credits. During the twelve months ended December 31, 2020, the Company recognized a benefit of $10.7 from the CARES Act. The benefit was recorded in operating income and was applied against the employer portion of payroll taxes. Certain non-U.S. jurisdictions have enacted similar stimulus measures focused on payroll incentives and tariff reductions. We continue to monitor any effects that may result from the CARES Act or other similar legislation globally. On December 21, 2020, the U.S. Congress enacted the Consolidated Appropriations Act of 2021, also known as "CARES Act 2." The Company is currently evaluating the impact of this new legislation on its consolidated financial statements.
The Company provides for deferred taxes on the undistributed earnings and profits of all foreign subsidiaries, determined under U.S. tax law. At December 31, 2020, the amount of undistributed earnings and profits of all foreign subsidiaries was $913.7. The Company anticipates that these foreign earnings and future earnings of its foreign subsidiaries that are not indefinitely reinvested will be sufficient to meet its U.S. cash needs. The Company is indefinitely reinvested in any excess of financial reporting over tax basis in its foreign subsidiaries that exceeds undistributed earnings and profits. At December 31, 2020, the indefinitely reinvested excess of financial reporting over tax basis was $240.9.
Deferred tax assets and liabilities include the following:
20202019
Deferred Tax Assets:
Loss carryforwards$128.6 $139.8 
Asbestos116.7 101.5 
Employee benefits64.7 59.4 
Accruals59.3 46.0 
Credit carryforwards3.4 2.5 
Other27.0 20.5 
Gross deferred tax assets399.7 369.7 
Less: Valuation allowance123.0 129.8 
Net deferred tax assets$276.7 $239.9 
Deferred Tax Liabilities:
Intangibles$(40.9)$(43.0)
Undistributed earnings(49.2)(33.8)
Accelerated depreciation(30.3)(26.9)
Investment0.5 (0.2)
Total deferred tax liabilities$(119.9)$(103.9)
Net deferred tax assets$156.8 $136.0 
Deferred taxes are presented in the Consolidated Balance Sheets as follows:
20202019
Non-current assets$158.3 $138.1 
Other non-current liabilities(1.5)(2.1)
Net deferred tax assets$156.8 $136.0 
The table included below provides a rollforward of our valuation allowance on net deferred income tax assets from December 31, 2017 to December 31, 2020.
StateForeignTotal
DTA valuation allowance - December 31, 2017$72.4 $97.6 $170.0 
  Change in assessment— (22.9)(22.9)
  Current year operations(15.1)9.0 (6.1)
DTA valuation allowance - December 31, 2018$57.3 $83.7 $141.0 
 Change in assessment— 5.6 5.6 
  Current year operations(8.8)(8.0)(16.8)
DTA valuation allowance - December 31, 2019$48.5 $81.3 $129.8 
  Change in assessment— (6.2)(6.2)
  Current year operations(8.1)7.5 (0.6)
DTA valuation allowance - December 31, 2020$40.4 $82.6 $123.0 
The Company continues to maintain a valuation allowance against certain deferred tax assets attributable to state net operating losses and tax credits, and certain foreign net deferred tax assets primarily in Luxembourg, China, and Germany which are not expected to be realized. Management assesses the available positive and negative evidence to estimate whether sufficient future taxable income will be generated to permit the use of deferred tax assets. The cumulative loss incurred over the three-year period ending December 31, 2020 constitutes significant objective negative evidence, resulting in the recognition of a valuation allowance against the net deferred tax assets for these jurisdictions. Such objective negative evidence limits our ability to consider subjective positive evidence, such as our projections of future taxable income. The amount of the deferred tax asset considered realizable, however, could be adjusted if estimates of future taxable income change or if objective negative evidence in the form of cumulative losses is no longer present and additional weight can be given to subjective evidence.
We have the following tax attributes available for utilization at December 31, 2020:
AttributeAmountFirst Year of Expiration
U.S. federal net operating losses$2.9 12/31/2037
U.S. state net operating losses915.7 12/31/2021
U.S. federal tax credits2.0 12/31/2029
U.S. state tax credits1.4 12/31/2027
Foreign net operating losses(a)
332.1 12/31/2021
(a) Includes approximately $224.9 of net operating loss carryforwards in Luxembourg as of December 31, 2020.
Excess tax benefits related to stock-based compensation of $3.0, $4.6 and $2.2 for 2020, 2019 and 2018, respectively, were recorded as an income tax benefit in the statement of operations and have been reflected in the caption “U.S. permanent items” within the effective tax rate reconciliation table.
Uncertain Tax Positions
We recognize income tax benefits from uncertain tax positions only if, based on the technical merits of the position, it is more likely than not that the tax position will be sustained on examination by the taxing authorities. The tax benefits recognized in the Consolidated Financial Statements from such positions are measured based on the largest benefit that has a greater than 50% likelihood of being realized upon ultimate settlement.
A reconciliation of the beginning and ending amount of unrecognized tax benefits for each of the years ended December 31, 2020, 2019, and 2018 is as follows:
202020192018
 Unrecognized tax benefits – January 1 $46.2 $45.8 $51.9 
 Additions for:
 Current year tax positions 0.9 1.5 1.5 
 Prior year tax positions 0.3 0.3 — 
 Reductions for:
 Prior year tax positions  (0.1)(0.2)
 Expiration of statute of limitations (4.7)(1.2)(1.9)
 Settlements (1.2)(0.1)(5.5)
 Unrecognized tax benefits – December 31 $41.5 $46.2 $45.8 
As of December 31, 2020, $16.7 and $0.5 of the unrecognized tax benefits would affect the effective tax rate for continuing operations and discontinued operations respectively, if realized. The Company operates in various tax jurisdictions and is subject to examination by tax authorities in these jurisdictions. The Company is currently under examination in several jurisdictions including the Czech Republic, Germany, Hong Kong, India, Italy, Japan, the U.S. and Venezuela. 
The calculation of our tax liability for unrecognized tax benefits includes dealing with uncertainties in the application of complex tax laws and regulations in various tax jurisdictions. Due to the complexity of some uncertainties, the ultimate resolution may result in a payment that is materially different from our current estimate of the unrecognized tax benefit. Over the next 12 months, the net amount of the tax liability for unrecognized tax benefits in foreign and domestic jurisdictions could change by approximately $15 due to changes in audit status, expiration of statutes of limitations and other events. The settlement of any future examinations could result in changes in the amounts attributable to the Company under its existing Tax Matters Agreement with Exelis and Xylem.
The following table summarizes the earliest open tax years by major jurisdiction as of December 31, 2020:
JurisdictionEarliest Open Year
China2015
Czech Republic2014
Germany2014
Hong Kong 2007
India2010
Italy2014
Korea2014
Luxembourg2015
Mexico2014
United States2017
We classify interest relating to tax matters as a component of interest expense and tax penalties as a component of income tax expense in our Consolidated Statements of Operations. During 2020, 2019, and 2018 we recognized a net interest benefit of $2.0, $0.3, and $0.9, respectively, related to tax matters. We had $0.9, $2.9, and $3.2 of interest expense accrued from continuing and discontinued operations related to tax matters as of December 31, 2020, 2019, and 2018, respectively.
Tax Matters Agreement
In relation to ITT's 2011 spin-off of its Defense and Information Solutions business, Exelis Inc. (Exelis), and its water-related business, Xylem Inc. (Xylem), ITT entered into a Tax Matters Agreement with Exelis and Xylem that governs the respective rights, responsibilities and obligations of the companies after the 2011 spin-off with respect to tax liabilities and benefits, tax attributes, tax contests and other tax sharing regarding U.S. Federal, state, local
and foreign income taxes, other tax matters and related tax returns. On May 29, 2015, Harris Corporation acquired Exelis and on June 29, 2019, Harris Corporation and L3 Technologies completed a merger. As of December 31, 2020, examinations remained open for income taxes from certain foreign jurisdictions. The settlement of future examinations and additional audit service fees may result in changes in amounts attributable to us through the Tax Matters Agreement entered into with Exelis and Xylem. Currently we cannot reasonably estimate the amount of such changes. ITT anticipates concluding all Tax Matters Agreement items in 2021.