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Income Tax
12 Months Ended
Dec. 31, 2022
Income Tax Disclosure [Abstract]  
Income Tax Income Tax
Our income (loss) before income taxes on which the provision for income taxes was computed is as follows:
 For the years ended
 December 31, 2022December 31, 2021December 31, 2020
 (In millions)
Domestic$228.4 $1,307.5 $1,151.7 
Foreign(290.9)(68.5)(1,795.6)
Total$(62.5)$1,239.0 $(643.9)
The components of the provision for income taxes are as follows:
 For the years ended
 December 31, 2022December 31, 2021December 31, 2020
 (In millions)
Current   
Federal$146.1 $43.5 $79.0 
State22.3 7.1 5.2 
Foreign(17.2)(1.0)111.4 
Total current tax (benefit) expense$151.2 $49.6 $195.6 
Deferred   
Federal$56.4 $163.5 $101.9 
State(26.2)70.4 19.5 
Foreign(57.4)(53.0)(15.2)
Total deferred tax (benefit) expense$(27.2)$180.9 $106.2 
Total income tax (benefit) expense$124.0 $230.5 $301.8 
A reconciliation from the U.S. statutory federal income tax rate to the effective income tax rate is as follows:
 For the years ended
 December 31, 2022December 31, 2021December 31, 2020
($ in millions)
Statutory federal income tax rate21.0 %$(13.1)21.0 %$260.2 21.0 %$(135.2)
State income taxes, net of federal benefits6.1 %(3.8)4.7 %57.8 (1.7)%11.0 
Effect of foreign tax rates92.6 %(57.9)(5.5)%(68.3)3.5 %(22.3)
Effect of foreign tax law and rate changes(0.8)%0.5 1.6 %19.6 (0.9)%6.0 
Effect of unrecognized tax benefits(20.5)%12.8 (6.2)%(76.3)(26.1)%167.9 
Change in valuation allowance1.1 %(0.7)(0.1)%(1.1)1.3 %(8.4)
Goodwill impairment(287.0)%179.3 (0.2)%(2.9)(41.4)%266.8 
Other, net(10.9)%6.9 3.3 %41.5 (2.6)%16.0 
Effective tax rate / Tax (benefit) expense(198.4)%$124.0 18.6 %$230.5 (46.9)%$301.8 
The decrease in the effective tax rate for fiscal year 2022 when compared to the statutory rate was primarily due to the impact of the $845 million partial goodwill impairment, recorded within our Americas segment in the fourth quarter of 2022, which related to goodwill not deductible for tax purposes.
The decrease to the effective tax rate for fiscal year 2021 when compared to the statutory rate was primarily due to the release of $73 million of reserves for unrecognized tax benefit positions recognized in the third quarter of 2021. The reserve release included amounts for an income tax audit settlement, net of changes in estimates associated with prior period uncertain tax positions, as well as amounts for the expiration of statutes of limitations. Additionally, during the second quarter of 2021, the U.K. government enacted, and royal assent was received for, legislation to increase the corporate income tax rate from 19% to 25%. Remeasurement of our deferred tax liabilities under the higher income tax rate resulted in the recognition of additional discrete tax expense of approximately $18 million in the second quarter of 2021.
The decrease to the effective tax rate for fiscal year 2020 when compared to the statutory rate was primarily due to the impact of the $1,484.3 million goodwill impairment, recorded within our EMEA&APAC segment in the fourth quarter of 2020, of which a majority related to nondeductible goodwill. Additionally, during the second quarter of 2020, we recognized approximately $135 million of tax expense following the enactment of the final U.S. tax hybrid regulations.
Additionally, our foreign businesses operate in jurisdictions with statutory income tax rates that differ from the U.S. Federal statutory rate. Specifically, the statutory income tax rates in the countries in Europe in which we operate range from 9% to 25.8%, and Canada has a combined federal and provincial statutory income tax rate of approximately 26%.
 As of
 December 31, 2022December 31, 2021
 (In millions)
Deferred tax assets 
Compensation-related obligations$44.7 $54.8 
Pension and postretirement benefits33.7 24.5 
Tax credit carryforwards39.0 38.3 
Tax loss carryforwards291.1 359.0 
Accrued liabilities and other149.0 97.7 
Valuation allowance(57.2)(60.7)
Deferred tax assets$500.3 $513.6 
Deferred tax liabilities  
Fixed assets358.9 422.4 
Partnerships and investments33.2 29.7 
Intangible assets2,563.2 2,539.7 
Derivative instruments31.5 19.5 
Deferred tax liabilities$2,986.8 $3,011.3 
Net deferred tax liabilities$2,486.5 $2,497.7 
Our deferred tax valuation allowances are primarily the result of uncertainties regarding the future realization of recorded tax benefits on tax loss carryforwards from operations in various jurisdictions. The measurement of deferred tax assets is reduced by a valuation allowance if, based upon available evidence, it is more likely than not that the deferred tax assets will not be realized. We have evaluated the realizability of our deferred tax assets in each jurisdiction by assessing the adequacy of expected taxable income, including the reversal of existing temporary differences, historical and projected operating results and the availability of prudent and feasible tax planning strategies. Based on this analysis, we have determined that the valuation allowances recorded in each period presented are appropriate.
We have deferred tax assets for U.S. tax loss and credit carryforwards that expire between 2023 and 2042 of $70.9 million and U.S. tax losses that may be carried forward indefinitely of $19.6 million. We have foreign tax loss and credit carryforwards that expire between 2023 and 2042 of $196.0 million and foreign tax losses that may be carried forward indefinitely of $38.3 million.
The following table presents our net deferred tax liabilities as of December 31, 2022 and December 31, 2021.
 As of
 December 31, 2022December 31, 2021
 (In millions)
Domestic deferred tax liabilities$1,927.7 $1,825.9 
Foreign deferred tax assets125.8 180.2 
Foreign deferred tax liabilities684.6 852.0 
Net deferred tax liabilities$2,486.5 $2,497.7 
The total foreign deferred tax assets above are presented within other assets on the consolidated balance sheets and domestic and foreign deferred tax liabilities above are presented within deferred tax liabilities on the consolidated balance sheets. The deferred tax liability amounts as of December 31, 2022 and December 31, 2021 excluded $34.0 million and $26.7 million, respectively, of unrecognized tax benefits that have been recorded as a reduction of deferred tax assets, which is presented within deferred tax liabilities due to jurisdictional netting on the consolidated balance sheets.
A reconciliation of the beginning and ending amounts of unrecognized tax benefits, excluding interest and penalties, is as follows:
 For the years ended
 December 31, 2022December 31, 2021December 31, 2020
 (In millions)
Balance at beginning of year$28.0 $235.7 $72.4 
Additions for tax positions related to the current year15.9 28.6 22.8 
Additions for tax positions of prior years1.9 — 132.1 
Reductions for tax positions related to the current year— (24.1)— 
Reductions for tax positions of prior years— (48.9)(1.6)
Settlements(3.7)(161.8)(0.4)
Release due to statute expirations(1.3)(3.4)— 
Foreign currency adjustment(1.5)1.9 10.4 
Balance at end of year$39.3 $28.0 $235.7 
Our remaining unrecognized tax benefits as of December 31, 2022, relate to tax years that are currently open to examination. As of December 31, 2022 and December 31, 2021, we have remaining unrecognized tax benefits recorded within other liabilities in our consolidated balance sheets of $5.4 million and $1.4 million, respectively. The remaining balance of our unrecognized tax benefits is recorded within deferred tax liabilities in our consolidated balance sheets. Annual tax provisions include amounts considered sufficient to pay assessments that may result from examination of prior year tax returns; however, the amount ultimately paid upon resolution of issues may differ materially from the amount accrued.
The Company recognizes interest and penalties related to unrecognized tax benefits as part of income taxes on our consolidated statements of operation. Expense (benefit) recognized on interest and penalties related to unrecognized tax benefits as of December 31, 2022, December 31, 2021, and December 31, 2020 was $(5.9) million, $1.4 million and $8.5 million, respectively. If the Company were to prevail on all uncertain tax positions, the reversal of this accrual, inclusive of interest and penalties, would result in a benefit of $31.5 million.
During the third quarter of 2021, an income tax audit settlement, which included the resolution of the impact of the final hybrid regulations recorded in the second quarter of 2020, was reached with taxing authorities. The settlement, along with changes to other unrecognized positions resulted in the net reduction of our unrecognized tax benefit position by approximately $250 million, including interest, in the third quarter of 2021. The cash tax payment associated with the settlement, after application of available net operating losses, was made in the fourth quarter of 2021 which totaled approximately $125 million. As of the fourth quarter of 2022, we do not anticipate material changes to our remaining unrecognized tax benefit position within the next 12 months.    
We file income tax returns in most of the federal, state and provincial jurisdictions in the U.S., Canada and various countries in Europe. Tax years through 2013 are closed in the U.S. In Canada, tax years through 2017 are closed or have been settled through examination except for issues relating to intercompany cross-border transactions. The statute of limitations for intercompany cross-border transactions is closed through tax year 2014. Tax years through 2014 are closed for most European jurisdictions in which we operate, with statutes of limitations varying from 3 to 7 years for most jurisdictions.
When cash is available after satisfying working capital needs and all other business obligations, we may distribute current earnings and the associated cash from a foreign subsidiary to its U.S. parent, and record the tax impact associated with the distribution. However, to the extent current earnings of our foreign operations exist and are not otherwise distributed or planned to be distributed, such earnings accumulate. These accumulated earnings are not considered permanently reinvested in our foreign operations. The taxes associated with any future repatriation of undistributed earnings are anticipated to be insignificant.