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Income Taxes
6 Months Ended
Jun. 30, 2021
Income Tax Disclosure [Abstract]  
Income Taxes

13.

INCOME TAXES

Income taxes are recognized for the amount of taxes payable or refundable for the current year and deferred tax liabilities and assets for the future tax consequences of events that have been recognized in our condensed consolidated financial statements or tax returns. The effects of income taxes are measured based on enacted tax laws and rates.

For the six months ended June 30, 2021 we had pretax income of $21.1 million and income tax expense of $11.2 million. The effective income tax rate for the period ended June 30, 2021 was unfavorably impacted primarily by $15.6 million in pretax losses in the U.S., which generated no tax benefit, and a $2.1 million unfavorable impact attributable to income tax rate increases in Germany and the United Kingdom.

For the six months ended June 30, 2021, we recorded a decrease in our valuation allowance of $0.6 million against our net deferred tax assets. In assessing the need for a valuation allowance, management considers all available positive and negative evidence in its analysis. Based on this analysis, we recorded a valuation allowance for the portion of deferred tax assets where the weight of the evidence indicated it is more likely than not that the deferred assets will not be realized.

As of June 30, 2021 and December 31, 2020, we had $48.3 million and $46.3 million, respectively, of gross unrecognized tax benefits. As of June 30, 2021, if such benefits were to be recognized, approximately $37.9 million would be recorded as a component of income tax expense, thereby affecting our effective tax rate.

We, or one of our subsidiaries, file income tax returns with the United States Internal Revenue Service, as well as various state and foreign authorities.

The following table summarizes, by major jurisdiction, tax years that remain subject to examination:

 

 

Open Tax Years

Jurisdiction

Examinations not

yet initiated

 

 

Examinations in

progress

 

 

 

 

 

United States

 

 

 

 

Federal

2014 - 2015;

2017 - 2020

 

 

N/A

State

2016 - 2020

 

 

2015 - 2018

Canada(1)

2013 - 2018; 2020

 

 

2019

Germany(1)

2020

 

 

2016 - 2019

France

2018 - 2020

 

 

N/A

United Kingdom

2019 - 2020

 

 

N/A

Philippines

2019 - 2020

 

 

2018

 

(1)

includes provincial or similar local jurisdictions, as applicable

The amount of income taxes we pay is subject to ongoing audits by federal, state and foreign tax authorities, which often result in proposed assessments. Management performs a comprehensive review of its global tax positions on a quarterly basis and accrues amounts for uncertain tax positions. Based on these reviews and the result of discussions and resolutions of matters with certain tax authorities and the closure of tax years subject to tax audit, reserves are adjusted as necessary. However, future results may include favorable or unfavorable adjustments to our estimated tax liabilities in the period the assessments are determined or resolved or as such statutes are closed. Due to potential for resolution of federal, state and foreign examinations, and the lapse of various statutes of limitation, it is reasonably possible our gross unrecognized tax benefits balance may decrease within the next twelve months by a range of zero to $6.4 million. Substantially all of this range relates to tax positions taken in the U.S.

We recognize interest and penalties related to uncertain tax positions as income tax expense. The following table summarizes information included in continuing operations related to interest on uncertain tax positions:

 

Six months ended

June 30

 

In millions

2021

 

 

 

2020

 

Interest expense (income)

$

0.4

 

 

 

$

0.2

 

 

 

June 30

 

 

 

December 31

 

 

2021

 

 

 

2020

 

Accrued interest payable

$

2.2

 

 

 

$

1.8