Income (loss) before income taxes for the years ended December 31, 2022, 2021 and 2020 is summarized as follows:


	2022			2021			2020
Income (loss) before income taxes:
United States	$	(203.8	)	$	(39.0	)	$	(51.6	)
Foreign		83.6			56.1			49.6
Total	$	(120.2	)	$	17.1		$	(2.0	)

Income tax provision for the years ended December 31, 2022, 2021 and 2020 is summarized as follows:


	2022			2021			2020
Current:
United States federal and state	$	(11.7	)	$	(1.2	)	$	(4.3	)
Foreign		10.9			7.9			16.6
Total current	$	(0.8	)	$	6.7		$	12.3
Deferred:
United States federal and state	$	(2.4	)	$	0.6		$	0.3
Foreign		6.6			(1.2	)		4.5
Total deferred	$	4.2		$	(0.6	)	$	4.8
Income tax provision	$	3.4		$	6.1		$	17.1

The items accounting for the difference between income taxes computed at the United States federal statutory rate and the Company's effective rate for the years ended December 31, 2022, 2021 and 2020 is summarized as follows:


	2022			2021			2020
Federal income tax at statutory rate	$	(25.2	)	$	3.6		$	(0.4	)
State income tax provision		0.9			0.3			1.9
Manufacturing and research incentives		(0.5	)		(0.2	)		(0.8	)
Taxes on foreign income which differ from the federal statutory rate		(1.9	)		1.5			—
Adjustments for unrecognized tax benefits		(11.0	)		(2.3	)		10.7
Adjustments for valuation allowances		5.2			4.5			22.2
United States tax reform		4.8			(1.6	)		(14.6	)
Goodwill impairment		31.7						—
Other items		(0.6	)		0.3			(1.9	)
Income tax provision	$	3.4		$	6.1		$	17.1

For the year ended December 31, 2022, the benefit for income taxes related to unrecognized tax benefits was primarily driven by a release of a $12.1 million uncertain tax position, inclusive of $1.2 million of interest, related to U.S. Federal tax planning strategies implemented as a result of the Coronavirus Aid, Relief and Economic Security Act. For the year ended December 31, 2021, the only significant item included in “other items” per the federal statutory reconciliation was a $1.9 million benefit relating to a 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 the years ended December 31, 2022 and 2020.

For the years ended December 31, 2022, 2021 and 2020 the Company recorded a net income tax inclusion for the global intangible low-taxed income (“GILTI”) in the amount of $22.9 million, $2.5 million and zero, respectively, which is fully offset by the valuation allowance recorded in the United States. 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 2020 and 2019. In 2021, the Company filed an amended return to adopt the regulations for the 2018 tax year, resulting in the recognition of a net income tax benefit of $1.6 million for the year ended December 31, 2021.

As of each reporting date, the Company considers new evidence, both positive and negative, that could impact its assessment related to future realization of deferred tax assets. The income tax provision for the year ended December 31, 2022 includes a $1.2 million income tax benefit for the release of a valuation allowance in India. As of December 31, 2022, the Company has recorded valuation allowances on deferred tax assets for certain legal entities in Brazil, China, Chile, Germany, Russia, the U.K. and the United States as it is more likely than not that the assets will not be realized. The income tax provision for the year ended December 31, 2021 includes a $7.2 million net increase to valuation allowances for other jurisdictions, partially offset by a $2.7 million income tax benefit for the partial release of a valuation allowance in China. The income tax provision for the year ended December 31, 2020 includes a $22.2 million net increase in valuation allowances for other jurisdictions.

It is reasonably possible that sufficient positive evidence required to release all, or a portion of, certain valuation allowances in the Company's German business within the next twelve months may result in a reduction of the valuation allowance of approximately $20.0 million. Such changes in the realizability of deferred tax assets will be reflected in continuing operations and could have a material effect on the Company’s financial position and results of operations.

Temporary differences and carryforwards that give rise to deferred tax assets and liabilities are summarized as follows:


	2022			2021
Deferred income tax assets:
Inventories	$	25.3		$	23.9
Deferred employee benefits		28.2			30.8
Product warranty reserves		8.7			8.9
Product liability reserves		2.2			2.0
Tax credits		7.2			7.4
Loss and other tax attribute carryforwards		129.6			151.1
Deferred revenue		0.2			2.4
Other		18.6			20.6
Total deferred income tax assets		220.0			247.1
Less valuation allowance		(174.1	)		(170.5	)
Net deferred income tax assets	$	45.9		$	76.6
Deferred income tax liabilities
Accounts receivable	$	4.0		$	1.5
Property, plant and equipment		5.1			23.0
Intangible assets		28.0			34.7
Total deferred income tax liabilities	$	37.1		$	59.2
Net deferred income tax assets	$	8.8		$	17.4

The net deferred tax assets reflected in the Consolidated Balance Sheets for the years ended December 31, 2022 and 2021 are summarized as follows:


	2022			2021
Long-term income tax assets, included in other non-current assets	$	13.7		$	23.9
Long-term deferred income tax liability		(4.9	)		(6.5	)
Net deferred income tax asset	$	8.8		$	17.4

The Company believes that certain offshore cash can be accessed in a tax efficient manner and therefore, as of December 31, 2022, deferred taxes were not provided on approximately $242.1 million of unremitted earnings of foreign subsidiaries that may be remitted to the United States without material tax cost. The Company had approximately $478.1 million and $481.5 million of cumulative foreign earnings as of December 31, 2022 and December 31, 2021, respectively, which are asserted to be permanently reinvested. Determination of the amount of unrecognized deferred tax liability related to these earnings is not practicable.

As of December 31, 2022, the Company had approximately $96.8 million of federal net operating loss carryforwards, which are available to reduce future federal tax liabilities. $13.5 million of the federal net operating loss carryforwards expire in 2036 and the remaining $83.3 million is not subject to any time restrictions for future use. As of December 31, 2021, the Company had approximately $189.0 million of federal loss carryforwards, which are available to reduce future 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 the 2022 and 2021 indefinite lived loss carryforwards is limited annually to 80% of adjusted taxable income. The carryforward was offset by a valuation allowance as of December 31, 2022 and 2021.

As of December 31, 2022 and 2021, the Company had approximately $26.8 million and $9.0 million, respectively, of federal interest expense carryforward that is not subject to any time restrictions for future use. The utilization of the interest expense carryforward is limited annually to 30% of adjusted taxable income. The carryforward was offset by a full valuation allowance as of December 31, 2022 and 2021.

As of December 31, 2022 and 2021, the Company had approximately $651.9 million and $772.0 million, respectively, of state net operating loss carryforwards, which are available to reduce future state tax liabilities. As of December 31, 2022 and 2021, these state net operating loss carryforwards expire at various times through 2042 and 2041, respectively. The carryforward was offset by a full valuation allowance as of December 31, 2022 and 2021.

As of December 31, 2022 and 2021, the Company had approximately $263.5 million and $281.2 million, respectively, of foreign loss carryforwards, which are available to reduce future foreign tax liabilities. Substantially all the foreign loss carryforwards have an indefinite carryforward period of which $163.7 million were offset by a valuation allowance as of December 31, 2022 and $151.9 million as of December 31, 2021.

The Company or one of its subsidiaries files income tax returns in the United States and certain foreign 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.

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, 2022, 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 costs, settlements, penalties and/or interest assessments, could be materially different from the Company’s accruals and could have a material effect on its financial position, results of operations and/or cashflows in the periods for which that determination is made.

During the years ended December 31, 2022, 2021 and 2020, the Company recorded an increase (decrease) to the gross unrecognized tax benefits including interest and penalties of $(11.0) million, $(2.1) million and $5.5 million, respectively, of which $(1.7) million, $(0.4) million and $(3.1) million, respectively, are a result of the net reductions to interest and penalties.

A reconciliation of the beginning and ending amount of unrecognized tax benefits excluding interest and penalties as of December 31, 2022, 2021 and 2020 are summarized as follows:


	2022			2021			2020
Balance at beginning of year	$	18.4		$	20.1		$	11.5
Additions for tax positions of current year		0.1			0.1			0.3
Additions for tax positions of prior years		3.6			—			10.9
Reductions for tax positions of prior years		(11.0	)		(0.2	)		(0.4	)
Reductions based on settlements with tax authorities		—			(0.2	)		(2.1	)
Reductions for lapse of statute of limitations		(2.0	)		(1.4	)		(0.1	)
Balance at end of year	$	9.1		$	18.4		$	20.1

As of December 31, 2022, 2021 and 2020, the Company accrued interest and penalties of $1.2 million, $2.9 million and $3.3 million, respectively.

Approximately $4.7 million, $14.0 million and $15.4 million of the Company’s unrecognized tax benefits as of December 31, 2022, 2021 and 2020, respectively, would impact the effective tax rate.

During the next twelve months, the unrecognized tax benefits are not expected to significantly increase or decrease due to audit settlements or lapsing statutes of limitations.