Income Taxes

The federal and state and foreign income tax provision is summarized as follows:



Year Ended December 31,	2012			2011			2010
Current
Federal	$	112,247		$	99,448		$	116,388
State	5,284			7,067			8,698
Foreign	4,511			4,603			3,365
	122,042			111,118			128,451
Deferred, including current deferred
Federal	(2,708		)	(2,317		)	6,085
State	(2,199		)	2,477			1,509
Foreign	3,970			6			—
	(937		)	166			7,594
Income taxes attributable to the Noncontrolling interest	357			553			416
Total income taxes	$	121,462		$	111,837		$	136,461

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 raised may differ materially from the amount accrued. The examination and the resolution process may last longer than one year.

The components of Net income before income taxes are summarized as follows:



Year Ended December 31,	2012		2011		2010
Domestic	$	319,907	$	309,391	$	360,937
Foreign	8,046		6,852		6,795
	$	327,953	$	316,243	$	367,732

The effective income tax rate differs from the federal income tax statutory rate due to the following:



Year Ended December 31,	2012		2011		2010
Statutory rate	35.0	%	35.0	%	35.0	%
State taxes, net of Federal tax benefit	1.0		2.0		2.0
Foreign tax expense and tax rate differential	1.6		0.6		0.4
Research and development tax credit	—		(0.7	)	(0.5	)
Domestic Production Activities Deduction	(0.6	)	(0.7	)	—
Valuation allowance on PA loss carryforwards	(0.3	)	—		—
Domestic Production Activities Deduction, prior years, net	—		(1.5	)	—
Net change in uncertain tax positions (1)	0.5		0.4		0.2
Other, net	(0.3	)	0.1		(0.1	)
	36.9	%	35.2	%	37.0	%

(1) For 2012, 0.15 percent relates to federal issues mainly associated with compilation of foreign tax credits, 0.33 percent relates to state tax issues and the remaining 0.02 percent relates to foreign tax issues. For 2011, 0.25 percent relates to federal issues, 0.14 percent relates to state tax issues and the remaining 0.01 percent relates to foreign tax issues. For 2010, 0.14 percent relates to federal issues and the remaining 0.06 percent relates to state tax issues.

Undistributed earnings of the Company’s foreign subsidiaries, except for SEI Asset Korea Co., Ltd. (SEI AK), amounted to approximately $47,385 at December 31, 2012. Those earnings are considered to be indefinitely reinvested and, accordingly, no U.S. federal and state income taxes have been provided thereon. Upon distribution of those earnings, in the form of dividends or otherwise, the Company would be subject to both U.S. income taxes, subject to an adjustment for foreign tax credits, and withholding taxes payable to the various foreign countries. Determination of the amount of unrecognized deferred U.S. income tax liability is not practicable because of the complexities associated with its hypothetical calculation, including the availability, or lack thereof, of foreign tax credits to reduce a portion of the U.S. liability. The Company no longer considers the earnings of SEI AK to be indefinitely reinvested and, therefore, has accrued U.S. deferred taxes on the cumulative undistributed earnings (See Note 15).

Deferred income taxes for 2012, 2011, and 2010 reflect the impact of temporary differences between the amount of assets and liabilities for financial reporting purposes and such amounts as measured by tax laws and regulations.

The net deferred income tax liability is comprised of:



Year Ended December 31,	2012			2011
Current deferred income taxes:
Gross assets	$	2,012		$	1,151
Gross liabilities	—			(1		)
	2,012			1,150
Valuation allowance	—			—
	2,012			1,150
Long-term deferred income taxes:
Gross assets	63,129			63,374
Gross liabilities	(149,708		)	(148,540		)
	(86,579		)	(85,166		)
Valuation allowance	(6,879		)	(8,585		)
	(93,458		)	(93,751		)
Net deferred income tax liability	$	(91,446	)	$	(92,601	)

The valuation allowances against deferred tax assets at December 31, 2012 and 2011 are related to state net operating losses from certain domestic subsidiaries. Certain state tax statutes significantly limit the utilization of net operating losses for domestic subsidiaries. Furthermore, these net operating losses cannot be used to offset the net income of other subsidiaries.

The tax effect of significant temporary differences representing deferred tax liabilities is:



Year Ended December 31,	2012			2011
Difference in financial reporting and income tax depreciation methods	$	(10,104	)	$	(13,600	)
Reserves not currently deductible	325			374
Capitalized software currently deductible for tax purposes, net of amortization	(137,467		)	(139,455		)
State deferred income taxes	5,943			6,717
Revenue and expense recognized in different periods for financial reporting and income tax purposes	4,397			3,149
Unrealized holding gain on investments	(1,428		)	(927		)
Stock-based compensation expense	42,133			43,879
State net operating loss carryforward	13,883			14,485
Valuation allowance on deferred tax assets	(6,879		)	(8,585		)
Federal benefit of state tax deduction for uncertain tax positions	2,359			1,725
Foreign currency exchange	(39		)	(363		)
Foreign deferred including taxes on cumulative undistributed earnings of SEI AK	(4,569		)	—
Net deferred income tax liability	$	(91,446	)	$	(92,601	)

The Company recognizes uncertain tax positions in accordance with the applicable accounting guidance and adjusts these liabilities when management’s judgment changes as a result of the evaluation of new information not previously available. Due to the complexity of some of these uncertainties, the ultimate resolution may result in a payment that is materially different than from our current estimate of the tax liabilities. The Company’s total unrecognized tax benefit, not including interest and penalties, as of December 31, 2012 was $11,553, of which $9,965 would affect the effective tax rate if the Company were to recognize the tax benefit. The gross amount of uncertain tax liability of $5,291 which is expected to be paid within one year is included in Current liabilities while the remaining amount of $7,032 is included in Other long-term liabilities on the accompanying Consolidated Balance Sheets. During the year ended December 31, 2012, the Company recognized $1,944 of previously unrecognized tax benefits relating to the lapse of the statute of limitation for certain state filings.

The Company files a consolidated federal income tax return and separate income tax returns with various states. Certain subsidiaries of the Company file tax returns in foreign jurisdictions. The Company is no longer subject to U.S. federal income tax examination for years before 2009 and is no longer subject to state, local or foreign income tax examinations by authorities for years before 2006.

A reconciliation of the beginning and ending amount of unrecognized tax benefit is as follows:



	2012			2011			2010
Balance as of January 1	$	9,410		$	5,723		$	4,989
Tax positions related to current year:
Gross additions	2,196			2,392			1,372
Gross reductions	—			—			—
	2,196			2,392			1,372
Tax positions related to prior years:
Gross additions	1,990			1,992			—
Gross reductions	—			—			(104		)
	1,990			1,992			(104		)
Settlements	(99		)	—			(102		)
Lapses on statute of limitations	(1,944		)	(697		)	(432		)
Balance as of December 31	$	11,553		$	9,410		$	5,723

The above reconciliation of the gross unrecognized tax benefit will differ from the amount which would affect the effective tax rate because of the recognition of the federal and state tax benefits.

The Company classifies all interest and penalties as income tax expense. The Company has recorded $770, $634 and $690 in liabilities for tax related interest and penalties in 2012, 2011, and 2010, respectively.

The Company estimates it will recognize $5,291 of unrecognized tax benefits within the next twelve months due to lapses on the statute of limitation and settlements.

The Company includes its direct and indirect subsidiaries in its U.S. consolidated federal income tax return. The Company’s tax sharing allocation agreement provides that any subsidiary having taxable income will pay a tax liability equivalent to what that subsidiary would have paid if it filed a separate income tax return. If the separately calculated federal income tax provision for any subsidiary results in a tax loss, the current benefit resulting from such loss, to the extent utilizable on a separate return basis, is accrued and paid to that subsidiary.