Income Taxes

The components of income before income taxes are listed below.



	Years ended December 31,
	2016		2015		2014
Domestic	$	504.7	$	461.0	$	387.7
Foreign	325.5		301.2		333.0
Total	$	830.2	$	762.2	$	720.7

The provision for income taxes is listed below.



	Years ended December 31,
	2016			2015			2014
U.S. federal income taxes (including foreign withholding taxes):
Current	$	54.3		$	117.8		$	8.0
Deferred	36.6			46.9			130.7
	90.9			164.7			138.7
State and local income taxes:
Current	8.2			15.1			9.7
Deferred	(1.5		)	13.0			23.8
	6.7			28.1			33.5
Foreign income taxes:
Current	89.8			100.4			115.3
Deferred	10.6			(10.4		)	(71.0		)
	100.4			90.0			44.3
Total	$	198.0		$	282.8		$	216.5

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,
	2016			2015			2014
U.S. federal statutory income tax rate	35.0		%	35.0		%	35.0		%

Income tax provision at U.S. federal statutory rate	$	290.6		$	266.8		$	252.3
State and local income taxes, net of U.S. federal income tax benefit	4.3			18.3			21.4
Impact of foreign operations, including withholding taxes	(23.9		)	14.7			0.9
Change in net valuation allowance ¹	(13.4		)	(20.6		)	(66.0		)
Divestitures	9.7			11.9			0.0
U.S. federal tax credits	(44.6		)	0.0			0.0
Stock compensation	(9.0		)	0.0			0.0
Increase/(decrease) in unrecognized tax benefits	(22.2		)	(6.5		)	5.2
Statutory tax rate changes	11.4			1.4			0.8
Other	(4.9		)	(3.2		)	1.9
Provision for income taxes	$	198.0		$	282.8		$	216.5

Effective income tax rate on operations	23.8		%	37.1		%	30.0		%


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

In 2016, our effective income tax rate of 23.8% was positively impacted by a benefit of $44.6 related to refunds to be claimed on future amended U.S. federal returns for tax years 2014 and 2015 primarily related to foreign tax credits and, to a lesser extent, research and development credits based on the conclusion of multi-year studies; the settlement of 2011 and 2012 income tax audits, which included the recognition of certain previously unrecognized tax benefits of $23.4; the reversal of valuation allowances of $12.2 as a consequence of the disposition of certain businesses in Continental Europe; $10.4 related to the early adoption of the FASB Accounting Standards Update 2016-09, Stock Compensation; and various changes in state income tax laws as well as the recognition of previously unrecognized state tax benefits as a result of a lapse in statute of limitations. The positive impacts to our tax rates were partially offset by a revaluation of deferred tax assets as a result of a statutory tax rate change in Continental Europe, losses in certain foreign jurisdictions where we receive no tax benefit due to 100% valuation allowances and by losses on sales of businesses for which we did not receive a full tax benefit.

In 2015, our effective income tax rate of 37.1% was negatively impacted primarily by losses in certain foreign jurisdictions where we receive no tax benefit due to 100% valuation allowances and from the losses on sales of businesses for which we did not receive a full tax benefit. The negative impacts to our tax rates were partially offset by the recognition of previously unrecognized tax benefits as a result of the reversal of valuation allowances in Continental Europe and the settlement of a 2010 income tax audit.

In 2014, our effective income tax rate of 30.0% was positively impacted from changes to our valuation allowances of $66.0. 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.

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



	December 31,
	2016			2015
Postretirement/post-employment benefits	$	23.1		$	25.3
Deferred compensation	192.4			193.4
Pension costs	36.6			25.8
Basis differences in fixed assets	(80.2		)	(67.5		)
Rent	41.7			41.1
Interest	58.9			60.9
Accruals and reserves	17.2			29.4
Allowance for doubtful accounts	13.3			10.8
Basis differences in intangible assets	(405.0		)	(408.2		)
Investments in equity securities	(6.3		)	(8.3		)
Tax loss/tax credit carry forwards	354.6			354.5
Prepaid expenses	(2.9		)	(2.3		)
Deferred revenue	(32.0		)	0.0
Other	44.3			60.3
Total deferred tax assets, net	255.7			315.2
Valuation allowance	(255.6		)	(275.1		)
Net deferred tax assets	$	0.1		$	40.1

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,
	2016			2015			2014
Balance at beginning of period	$	275.1		$	332.2		$	467.3
Reversed to costs and expenses	(15.4		)	(20.8		)	(72.8		)
Charged (reversed) to gross tax assets and other accounts ¹	9.5			(9.2		)	(26.4		)
Foreign currency translation	(13.6		)	(27.1		)	(35.9		)
Balance at end of period	$	255.6		$	275.1		$	332.2


1	Primarily represents changes to the valuation allowance related to the change of a corresponding deferred tax asset.

In both 2016 and 2015, amounts reversed to costs and expenses primarily related to decreases in valuation allowances in Continental Europe for existing deferred tax assets.

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.

As of December 31, 2016, there were $1,012.3 of loss carryforwards. These loss carryforwards were all non-U.S. tax loss carryforwards, of which $889.1 have unlimited carryforward periods and $123.2 have expiration periods from 2017 to 2036. As of December 31, 2016, the Company also had $55.6 in deferred tax assets for state net operating loss carryforwards and tax credit carryforwards, which will expire between 2017 and 2036.

As of December 31, 2016 and 2015, we had $2,622.4 and $2,592.4, 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 deferred income tax liability on these undistributed earnings because such liability, if any, is dependent on circumstances that exist if and when a remittance occurs, including the source location and amount of the distribution, the underlying tax rate already paid on the earnings, foreign withholding taxes and the opportunity to use foreign tax credits.

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



	Years ended December 31,
	2016			2015			2014
Balance at beginning of period	$	226.9		$	238.0		$	219.2
Increases as a result of tax positions taken during a prior year	65.0			5.2			29.0
Decreases as a result of tax positions taken during a prior year	(47.5		)	(19.7		)	(16.3		)
Settlements with taxing authorities	(4.6		)	(4.1		)	(1.1		)
Lapse of statutes of limitation	(11.8		)	(3.8		)	(4.1		)
Increases as a result of tax positions taken during the current year	18.7			11.3			11.3
Balance at end of period	$	246.7		$	226.9		$	238.0

Included in the total amount of unrecognized tax benefits of $246.7 as of December 31, 2016, is $221.0 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, 2016 and 2015 is $20.9 and $20.1, respectively, of which a detriment of $0.7 and $4.8 is included in our 2016 and 2015 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.

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. federal income tax audits through 2012, with the exception of 2009. With limited exceptions, we are no longer subject to state and local income tax audits for years prior to 2007 or non-U.S. income tax audits for years prior to 2006.