Income (loss) before income taxes for the years ended December 31, 2021, 2020 and 2019 is summarized as follows:


	2021			2020			2019
Income (loss) before income taxes:
U.S.	$	(39.0	)	$	(51.6	)	$	(10.0	)
Non-U.S.		56.1			49.6			69.0
Total	$	17.1		$	(2.0	)	$	59.0

Income tax provision (benefit) for the years ended December 31, 2021, 2020 and 2019 is summarized as follows:


	2021			2020			2019
Current:
U.S. federal and state	$	(1.2	)	$	(4.3	)	$	(0.7	)
Non-U.S.		7.9			16.6			11.6
Total current	$	6.7		$	12.3		$	10.9
Deferred:
U.S. federal and state	$	0.6		$	0.3		$	0.2
Non-U.S.		(1.2	)		4.5			1.3
Total deferred	$	(0.6	)	$	4.8		$	1.5
Income tax provision	$	6.1		$	17.1		$	12.4

The calculated U.S. federal income tax amount at the statutory rate of 21% is reconciled to the Company’s income tax provision (benefit) for the years ended December 31, 2021, 2020 and 2019.


	2021			2020			2019
U.S. federal income tax at statutory rate	$	3.6		$	(0.4	)	$	12.4
U.S. state income tax provision		0.3			1.9			(0.1	)
Manufacturing and research incentives		(0.2	)		(0.8	)		(3.0	)
Taxes on non-U.S. income which differ from the U.S. statutory rate		1.5			—			(2.6	)
Adjustments for unrecognized tax benefits		(2.3	)		10.7			(1.3	)
Adjustments for valuation allowances		4.5			22.2			4.5
U.S. tax reform		(1.6	)		(14.6	)		4.0
Other items		0.3			(1.9	)		(1.5	)
Income tax provision	$	6.1		$	17.1		$	12.4

For the years ended December 31, 2021, 2020 and 2019, the Company recorded an income tax inclusion for the global intangible low-taxed income (“GILTI”) in the amount of $2.5 million, zero and $22.7 million, respectively, which is fully offset by the valuation allowance recorded in the U.S. The GILTI inclusion for each respective year is reflective of the final regulations issued in 2020 relating to Internal Revenue Code Section 951A and the treatment of foreign income subject to a high tax rate. While effective beginning in 2021, the regulations allowed for retroactive application which the Company elected in the period of issuance for 2019 and 2020. In 2021, the Company filed an amended return to adopt the regulations for the 2018 tax year, resulting in a net income tax benefit of $1.6 million recorded for the year ended December 31, 2021.

As of each reporting date, the Company considers new evidence, both positive and negative, that could impact management's assessment related to future realization of deferred tax assets.

As of December 31, 2021, the Company has recorded valuation allowances on the deferred tax assets for certain legal entities in Brazil, China, Germany, India, U.K. and the U.S. as it is more likely than not that the assets will not be realized. The 2021 income tax provision includes a $2.7 million income tax benefit for the partial valuation allowance release in China which is offset by a $6.9 million increase to the valuation allowance for other jurisdictions. The 2019 and 2020 income tax provisions were impacted by a net increase of $4.5 million and $22.2 million, respectively, related to additional valuation allowances recorded in various jurisdictions.

The Company will continue to evaluate the realizability of its deferred tax assets and may adjust its valuation allowances based on changes in facts and circumstances. It is reasonably possible that the Company will either increase or decrease a portion of its existing valuation allowances in the future. Such changes in the realizability of deferred tax assets will be reflected in continuing operations and could have a material effect on operating results.

During 2021, the only significant item included within the other items per the U.S. federal statutory reconciliation is a $1.9 million benefit relating to the French income tax refund as a result of a Mutually Agreed upon Procedure for 2006 between the Italian and French tax authorities. There were no significant items included in other items for 2020 and the only significant item included in the 2019 other items was the favorable resolution of the German income tax audit in the amount of $0.8 million.

Temporary differences and carryforwards that give rise to deferred tax assets and liabilities include the following items:


	2021			2020
Deferred income tax assets:
Inventories	$	23.9		$	22.8
Deferred employee benefits		30.8			34.7
Product warranty reserves		8.9			9.3
Product liability reserves		2.0			2.0
Tax credits		7.4			7.7
Loss and other tax attribute carryforwards		151.1			142.6
Deferred revenue		2.4			3.9
Other		20.6			18.0
Total deferred income tax assets		247.1			241.0
Less valuation allowance		(170.5	)		(171.4	)
Net deferred income tax assets	$	76.6		$	69.6
Deferred income tax liabilities
Accounts receivable		1.5			2.7
Property, plant and equipment		23.0			17.2
Intangible assets		34.7			36.0
Total deferred income tax liabilities	$	59.2		$	55.9
Net deferred income tax assets	$	17.4		$	13.7

The net deferred tax assets reflected in the Consolidated Balance Sheets for the years ended December 31, 2021 and 2020 are as follows:


	2021			2020
Long-term income tax assets, included in other non-current assets	$	23.9		$	19.6
Long-term deferred income tax liability		(6.5	)		(5.9	)
Net deferred income tax asset	$	17.4		$	13.7

The Company believes that certain offshore cash can be accessed in a tax efficient manner and therefore, as of December 31, 2021, $0.8 million of deferred taxes were provided on approximately $245.5 million of unremitted earnings of non-U.S. subsidiaries that may be remitted to the U.S. As of December 31, 2020, $0.9 million of deferred taxes were provided on approximately $239.4 million of unremitted earnings of non-U.S. subsidiaries that may be remitted to the U.S. The Company has approximately $481.5 million of foreign earnings as of December 31, 2021 which are asserted to be permanently reinvested. Determination of the amount of unrecognized deferred tax liability related to these earnings is not practicable.

The Company has approximately $189.0 million of U.S. federal loss carryforwards, which are available to reduce future U.S. federal tax liabilities. $24.4 million of the federal net operating loss carryforward expire in 2036 and the remaining $164.6 million is not subject to any time restrictions for future use. However, utilization of these indefinite lived loss carryforwards is annually limited to 80% of adjusted taxable income. The carryforward is offset by a valuation allowance.

The Company has approximately $9.0 million of U.S. federal interest expense carryforwards that is not subject to any time restrictions for future use. The utilization of the interest expense carryforwards is annually limited to 30% of adjusted taxable income. The carryforward is offset by a full valuation allowance.

The Company has approximately $772.0 million of U.S. state net operating loss carryforwards, which are available to reduce future U.S. state tax liabilities. These U.S. state net operating loss carryforwards expire at various times through 2041. The Company has recorded a full valuation allowance related to the U.S. state net operating losses.

The Company has approximately $281.2 million of non-U.S. loss carryforwards, which are available to reduce future non-U.S. tax liabilities. Substantially all the non-U.S. loss carryforwards have an indefinite carryforward period of which $151.9 million are offset by a valuation allowance.

The Company or one of its subsidiaries files income tax returns in the U.S. federal, U.S. state and non-U.S. jurisdictions. The following table provides the open tax years for which the Company could be subject to income tax examination by the tax authorities in its major jurisdictions:

During 2021, the Company closed the audit with the German tax authorities for calendar years 2015 to 2017. There have been no significant developments with respect to the Company’s ongoing tax audits in other the U.S. federal, state and non-U.S. jurisdictions.

The Company regularly assesses the likelihood of an adverse outcome resulting from examinations to determine the adequacy of its tax reserves. As of December 31, 2021, the Company believes that it is more likely than not that the tax positions it has taken will be sustained upon the resolution of its audits resulting in no material impact on its consolidated financial position and the results of operations and cashflows. However, the final determination with respect to any tax audits, including any related litigation, could be materially different from the Company’s accruals and could have a material effect on operating results and/or cashflows in the periods for which that determination is made. In addition, future period earnings may be adversely impacted by litigation costs, settlements, penalties and/or interest assessments.

During the years ended December 31, 2021, 2020 and 2019, the Company recorded an increase (decrease) to the gross unrecognized tax benefits including interest and penalties of $(2.1) million, $5.5 million and $1.7 million, respectively, of which $(0.4) million, $(3.1) million and $(0.3) million, respectively, are a result of the net reductions to interest and penalties.

As of December 31, 2021, 2020 and 2019, the Company has accrued interest and penalties of $2.9 million, $3.3 million and $6.4 million, respectively.

A reconciliation of the beginning and ending amount of unrecognized tax benefits excluding interest and penalties for the years ended December 31, 2021, 2020 and 2019 is as follows:


	2021			2020			2019
Balance at beginning of year	$	20.1		$	11.5		$	12.8
Additions for tax positions of current year		0.1			0.3			0.5
Additions for tax positions of prior years		—			10.9			0.3
Reductions for tax positions of prior years		(0.2	)		(0.4	)		—
Reductions based on settlements with tax authorities		(0.2	)		(2.1	)		(0.6	)
Reductions for lapse of statute of limitations		(1.4	)		(0.1	)		(1.5	)
Balance at end of year	$	18.4		$	20.1		$	11.5

The decrease in unrecognized tax benefits excluding interest and penalties primarily relates to $1.4 million of foreign reserves released due to the closing of statues of limitations.

Approximately $14.0 million, $15.4 million and $7.2 million of the Company’s unrecognized tax benefits as of December 31, 2021, 2020 and 2019, respectively, would impact the effective tax rate.

During the next twelve months, the unrecognized tax benefits are not expected to significantly increase or decrease because the Company’s tax positions are sustained on audit or settled, or the applicable statute of limitations closes.