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Income Tax
9 Months Ended
Sep. 24, 2011
Income Tax Disclosure [Abstract] 
Income Tax
Income Tax
Our effective tax rates for the third quarters of 2011 and 2010 were approximately 14% and 19%, respectively. For the first three quarters of 2011 and 2010, our effective tax rates were approximately 15% and 18%, respectively. The decrease from 2010 is primarily due to the tax effects of MillerCoors special charges in the third quarter of 2011 and the tax effect of Foster's total return swap unrealized gain of $42.3 million in the third quarter of 2010.
Our tax rate is volatile and may fluctuate with changes in, among other things, the amount and source of income or loss, our ability to utilize foreign tax credits, changes in tax laws, and the movement of liabilities established for uncertain tax positions as statutes of limitations expire or positions are otherwise effectively settled. There are proposed or pending tax law changes in the U.S., U.K. and Canada that, if enacted, may impact our effective tax rate.
As of December 25, 2010, we had $84.1 million of uncertain tax benefits. Since December 25, 2010, uncertain tax benefits increased by $6.1 million. This addition is net of increases due to additional uncertain tax benefits and interest accrued for the current year and decreases primarily due to certain tax positions closing or being effectively settled, and payments made to tax authorities with regard to uncertain tax benefits during the third quarter of 2011. This results in a total uncertain tax benefit of $90.2 million as of September 24, 2011.
During the remainder of 2011, we will recognize Canadian dollar ("CAD") 18.6 million of non-cash income tax benefit due primarily to the favorable resolution of unrecognized tax positions that we effectively settled early in the fourth quarter.
We file income tax returns in most of the federal, state, and provincial jurisdictions in the U.S., U.K., and Canada. In the U.S., tax years through 2006 are closed, while exam years 2007 and 2008 have been effectively settled and only remain open pending finalization of an advanced pricing agreement. Tax years through fiscal year ended February 8, 2005, are closed or have been effectively settled through examination in Canada. Tax years through 2008 are closed or have been effectively settled through examination in the U.K.