Income Taxes

The components of income before income taxes are listed below.



	Years ended December 31,
	2014		2013		2012
Domestic	$	387.7	$	255.3	$	386.9
Foreign	333.0		212.7		287.9
Total	$	720.7	$	468.0	$	674.8

The provision for income taxes is listed below.



	Years ended December 31,
	2014			2013			2012
U.S. federal income taxes (including foreign withholding taxes):
Current	$	8.0		$	46.9		$	9.4
Deferred	130.7			25.2			118.1
	138.7			72.1			127.5
State and local income taxes:
Current	9.7			(14.7		)	17.1
Deferred	23.8			24.7			25.3
	33.5			10.0			42.4
Foreign income taxes:
Current	115.3			79.6			83.2
Deferred	(71.0		)	19.5			(39.8		)
	44.3			99.1			43.4
Total	$	216.5		$	181.2		$	213.3

A reconciliation of the effective income tax rate as reflected in our Consolidated Statements of Operations to the U.S. federal statutory income tax rate is listed below.



	Years ended December 31,
	2014			2013			2012
U.S. federal statutory income tax rate	35.0		%	35.0		%	35.0		%

Income tax provision at U.S. federal statutory rate	$	252.3		$	163.8		$	236.2
	21.4			6.5			27.3
Impact of foreign operations, including withholding taxes	1.7			30.5			8.4
Change in net valuation allowance ¹	(66.0		)	3.2			(57.3		)
Worthless securities deduction	0.0			(22.2		)	0.0
Increases in unrecognized tax benefits, net	5.2			0.0			24.1
Other	1.9			(0.6		)	(25.4		)
Provision for income taxes	$	216.5		$	181.2		$	213.3
Effective income tax rate on operations	30.0		%	38.7		%	31.6		%


1	Reflects changes in valuation allowance that impacted the effective income tax rate for each year presented.

In 2014, our effective income tax rate of 30.0% was positively impacted from changes to our valuation allowances of $66.0 million. The primary drivers of the net change were associated with a valuation allowance reversal of $124.8 in one jurisdiction partially offset by the establishment of a valuation allowance of $57.2 in another jurisdiction, both in Continental Europe. In addition, our effective income tax rate was negatively impacted by losses in certain foreign jurisdictions where we receive no tax benefit due to 100% valuation allowances.

In 2013, our effective income tax rate of 38.7% was positively impacted by the recognition of previously unrecognized tax benefits as a result of the recognition of losses attributable to worthless securities in a consolidated subsidiary and the settlement of the 2002-2006 New York State audit cycle. Our effective income tax rate was negatively impacted primarily by losses in certain foreign jurisdictions where we receive no tax benefit due to 100% valuation allowances.

In 2012, our effective income tax rate of 31.6% was positively impacted by the reversals of valuation allowances associated with the Asia Pacific and Continental Europe regions, of $26.2 and $21.8, respectively, as well as by a benefit derived from the deduction of foreign tax credits that previously had a full valuation allowance. Our effective income tax rate was negatively impacted by an adjustment of $19.5 associated with the establishment of a previously unrecorded reserve for a tax contingency for the years 2007 through 2010, losses in certain foreign locations where we receive no tax benefit due to 100% valuation allowances and state and local income taxes, net of federal income tax benefit.

The components of deferred tax assets and liabilities are listed below.



	December 31,
	2014			2013
Postretirement/post-employment benefits	$	27.4		$	32.5
Deferred compensation	191.2			187.2
Pension costs	41.4			31.1
Basis differences in fixed assets	(38.5		)	(4.1		)
Rent	45.8			50.7
Interest	60.9			60.7
Accruals and reserves	34.8			39.6
Allowance for doubtful accounts	10.8			10.8
Basis differences in intangible assets	(412.3		)	(402.2		)
Investments in equity securities	(2.6		)	48.6
Tax loss/tax credit carry forwards	404.4			443.6
Restructuring and other reorganization-related costs	(0.3		)	2.6
Other	59.2			60.5
Total deferred tax assets, net	422.2			561.6
Valuation allowance	(332.2		)	(467.3		)
Net deferred tax assets	$	90.0		$	94.3

We evaluate the realizability of our deferred tax assets on a quarterly basis. The realization of our deferred tax assets is primarily dependent on future earnings. The amount of the deferred tax assets considered realizable could be reduced or increased in the near future if estimates of future taxable income are lower or greater than anticipated. A valuation allowance is established when it is “more likely than not” that all or a portion of deferred tax assets will not be realized. In circumstances where there is negative evidence, establishment of a valuation allowance is considered. The factors used in assessing valuation allowances include all available evidence, such as past operating results, estimates of future taxable income and the feasibility of tax planning strategies. We believe that cumulative losses in the most recent three-year period represent significant negative evidence, and as a result, we determined that certain of our deferred tax assets required the establishment of a valuation allowance. The deferred tax assets for which an allowance was recognized relate primarily to state and foreign tax loss carryforwards.

The change in the valuation allowance is listed below.



	Years ended December 31,
	2014			2013		2012
Balance at beginning of period	$	467.3		$	392.9	$	489.9
(Reversed) charged to costs and expenses	(72.8		)	65.2		(49.5		)
(Reversed) charged to gross tax assets and other accounts	(62.3		)	9.2		(47.5		)
Balance at end of period	$	332.2		$	467.3	$	392.9

In 2014, the net decrease was primarily related to a reversal of a valuation allowance for a deferred tax asset of $124.8, where we believe it is now "more likely than not" that the corresponding tax losses will be utilized over an extended period of time, based on implementing an internal financing tax action plan. This was partially offset by the establishment of a valuation allowance of $57.2, where we believe it is no longer "more likely than not" that the corresponding tax losses will be utilized, based on forecasted income not exceeding historical cumulative losses. The amounts charged to gross tax assets and other accounts relate primarily to the effect of foreign currency translation and a reduction to the valuation allowance related to the write-down of a corresponding deferred tax asset.

In 2013, amounts charged to costs and expenses primarily relate to the increase in valuation allowances in the U.S. and Continental Europe regions for existing and additional deferred tax assets. The amounts charged to gross tax assets and other accounts relate primarily to the effect of foreign currency translation.

In 2012, amounts reversed to costs and expenses primarily relate to the net reversal of valuation allowances in the Asia Pacific and Continental Europe regions, based on positive evidence in the form of a sustained pattern of profitability. Amounts reversed to gross tax assets and other accounts relate primarily to the reversal of valuation allowance on foreign tax credits.

As of December 31, 2014, there are $1,263.1 of loss carryforwards. These loss carryforwards are all non-U.S. tax loss carryforwards, of which $1,053.4 have unlimited carryforward periods and $209.7 have expiration periods from 2015 to 2033. As of December 31, 2014, the Company also had $60.3 in deferred tax assets for state net operating loss carryforwards and tax credit carryforwards, which will expire between 2015 and 2034.

As of December 31, 2014 and 2013, we had $2,214.2 and $1,959.8, respectively, of undistributed earnings attributable to foreign subsidiaries. It is our intention to permanently reinvest undistributed earnings of our foreign subsidiaries. We have not provided deferred U.S. income taxes or foreign withholding taxes on temporary differences resulting from earnings for certain foreign subsidiaries which are permanently reinvested outside the U.S. It is not practicable to determine the amount of unrecognized deferred tax liability associated with these temporary differences.

The table below summarizes the activity related to our unrecognized tax benefits.



	December 31,
	2014			2013			2012
Balance at beginning of period	$	219.2		$	194.6		$	161.0
Increases as a result of tax positions taken during a prior year	29.0			8.3			28.2
Decreases as a result of tax positions taken during a prior year	(16.3		)	(1.9		)	(6.8		)
Settlements with taxing authorities	(1.1		)	(34.9		)	(0.7		)
Lapse of statutes of limitation	(4.1		)	(10.6		)	(1.1		)
Increases as a result of tax positions taken during the current year	11.3			63.7			14.0
Balance at end of period	$	238.0		$	219.2		$	194.6

Included in the total amount of unrecognized tax benefits of $238.0 as of December 31, 2014, is $213.5 of tax benefits that, if recognized, would impact the effective income tax rate. The total amount of accrued interest and penalties as of December 31, 2014 and 2013 is $15.3 and $11.9, respectively, of which a detriment of $5.4 and $2.8 is included in our 2014 and 2013 Consolidated Statements of Operations, respectively. In accordance with our accounting policy, interest and penalties accrued on unrecognized tax benefits are classified as income taxes in our Consolidated Statements of Operations.

In 2013, we settled the 2002-2006 NYS audit cycle. The settlement resulted in a minor cash payment and our effective income tax rate was positively impacted by the recognition of previously unrecognized tax benefits.

We have various tax years under examination by tax authorities in the U.S., in various countries, and in various states, such as New York, in which we have significant business operations. It is not yet known whether these examinations will, in the aggregate, result in our paying additional taxes. We believe our tax reserves are adequate in relation to the potential for additional assessments in each of the jurisdictions in which we are subject to taxation. We regularly assess the likelihood of additional tax assessments in those jurisdictions and, if necessary, adjust our reserves as additional information or events require.

With respect to all tax years open to examination by U.S. federal, various state and local, and non-U.S. tax authorities, we currently anticipate that total unrecognized tax benefits will decrease by an amount between $25.0 and $35.0 in the next twelve months, a portion of which will affect our effective income tax rate, primarily as a result of the settlement of tax examinations and the lapsing of statutes of limitations. This net decrease is related to various items of income and expense, primarily transfer pricing adjustments.

We are effectively settled with respect to U.S. income tax audits for years prior to 2009. With limited exceptions, we are no longer subject to state and local income tax audits for years prior to 2004, or non-U.S. income tax audits for years prior to 2006.