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Income Taxes
6 Months Ended
Jul. 01, 2016
Income Tax Disclosure [Abstract]  
Income Taxes
INCOME TAXES
The Company’s effective tax rate from continuing operations for the three and six month periods ended July 1, 2016 was 32.2% and 29.7%, respectively, as compared to 21.2% and 22.1% for the three and six month periods ended July 3, 2015, respectively.
The Company's effective tax rate for 2016 and 2015 differs from the U.S. federal statutory rate of 35.0% due principally to the Company’s earnings outside the United States that are indefinitely reinvested and taxed at rates lower than the U.S. federal statutory rate. A higher tax rate associated with the gain on the sale of marketable equity securities during the first quarter of 2016 resulted in a 1.0% increase in the reported tax rate on a year-over-year basis for the six month period ended July 1, 2016. The Company also incurred $99 million of income tax expense related to repatriation of earnings and legal entity realignments associated with the Separation and other discrete items during both the three and six month periods ended July 1, 2016, which will continue to be reported in the Company’s continuing operations after the Separation. In addition, the Company recorded $20 million and $17 million in discrete Separation and other tax benefits in the three and six month periods ended July 1, 2016, respectively, that will be reported as discontinued operations in future periods. These matters increased the reported tax rate 8.2% and 4.1% for the three and six month periods, respectively. The effective tax rate for the three and six month periods ended July 3, 2015 also included tax effects of certain other discrete items specific to the periods, none of which are significant individually or in the aggregate.
Tax authorities in Denmark have raised significant issues related to interest accrued by certain of the Company's subsidiaries. On December 10, 2013, the Company received assessments from the Danish tax authority (“SKAT”) totaling approximately DKK 1.3 billion including interest through July 1, 2016 (approximately $197 million based on the exchange rate as of July 1, 2016), imposing withholding tax relating to interest accrued in Denmark on borrowings from certain of the Company's subsidiaries for the years 2004-2009. If the SKAT claims are successful, it is likely that the Company would be assessed additional amounts for the years 2010-2012 totaling approximately DKK 776 million including interest through July 1, 2016 (approximately $116 million based on the exchange rate as of July 1, 2016). Management believes the positions the Company has taken in Denmark are in accordance with the relevant tax laws and intends to vigorously defend its positions. The Company appealed these assessments with the National Tax Tribunal in 2014 and intends on pursuing this matter through the European Court of Justice should this appeal be unsuccessful. The ultimate resolution of this matter is uncertain, could take many years, and could result in a material adverse impact to the Company's financial statements, including its effective tax rate.