Income (loss) before income taxes for the years ended December 31, 2023, 2022 and 2021 is summarized as follows:


	2023			2022			2021
Income (loss) before income taxes:
United States	$	(32.7	)	$	(203.8	)	$	(39.0	)
Foreign		76.9			83.6			56.1
Total	$	44.2		$	(120.2	)	$	17.1

Provision for income taxes for the years ended December 31, 2023, 2022 and 2021 is summarized as follows:


	2023			2022			2021
Current:
United States federal and state	$	0.3		$	(11.7	)	$	(1.2	)
Foreign		10.7			10.9			7.9
Total current		11.0			(0.8	)		6.7
Deferred:
United States federal and state		—			(2.4	)		0.6
Foreign		(6.0	)		6.6			(1.2	)
Total deferred		(6.0	)		4.2		$	(0.6	)
Provision for income taxes	$	5.0		$	3.4		$	6.1

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, 2023, 2022 and 2021 is summarized as follows:


	2023			2022			2021
Federal income tax at statutory rate	$	9.3		$	(25.2	)	$	3.6
State income tax provision		2.0			0.9			0.3
Manufacturing and research incentives		(1.3	)		(0.5	)		(0.2	)
Taxes on foreign income which differ from the federal statutory rate		9.1			(1.9	)		1.5
Adjustments for unrecognized tax benefits		0.2			(11.0	)		(2.3	)
Adjustments to valuation allowances		(28.6	)		5.2			4.5
United States tax reform		10.1			4.8			(1.6	)
Goodwill and indefinite-lived intangible asset impairment		—			31.7			—
Audit settlements		(3.0	)		—			(1.9	)
Non-deductible expenses		8.2			1.6			1.3
Other items		(1.0	)		(2.2	)		0.9
Provision for income taxes	$	5.0		$	3.4		$	6.1

For the year ended December 31, 2023, the provision for income taxes was favorably impacted by the release of a $19.0 million valuation allowance, and a $3.2 million tax benefit for the favorable resolution of a previously reserved foreign income tax matter. These benefits were partially offset by the tax effect of $8.2 million related to non-deductible expenses. 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 provision for income taxes was favorably impacted by a $1.9 million 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, 2023, 2022 and 2021.

For the years ended December 31, 2023, 2022 and 2021 the Company recorded a net income tax inclusion for the global intangible low-taxed income (“GILTI”) in the amount of $48.0 million, $22.9 million and $2.5 million, 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 2019 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 provision for income taxes for the year ended December 31, 2023 includes a $19.0 million income tax benefit for the release of a valuation allowance. 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. 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. As of December 31, 2023, the Company has recorded valuation allowances on deferred tax assets for certain legal entities in Brazil, China, Chile, Russia, the U.K. and the United States as it is more likely than not that the assets will not be realized.

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


	2023			2022
Deferred income tax assets:
Inventories	$	14.7		$	25.3
Deferred employee benefits		27.8			28.2
Product warranty reserves		7.8			8.7
Product liability reserves		2.6			2.2
Tax credits		7.9			7.2
Loss and other tax attribute carryforwards		114.1			129.6
Deferred revenue		3.9			0.2
Capitalized research costs		10.5			4.8
Other		12.5			13.8
Total deferred income tax assets		201.8			220.0
Less valuation allowance		(130.8	)		(174.1	)
Net deferred income tax assets	$	71.0		$	45.9
Deferred income tax liabilities
Accounts receivable	$	—		$	4.0
Property, plant and equipment		25.6			5.1
Intangible assets		28.5			28.0
Total deferred income tax liabilities	$	54.1		$	37.1
Net deferred income tax assets	$	16.9		$	8.8

The net deferred tax assets reflected in the Consolidated Balance Sheets for the years ended December 31, 2023 and 2022 are summarized as follows:


	2023			2022
Long-term income tax assets, included in other non-current assets	$	24.4		$	13.7
Long-term deferred income tax liability		(7.5	)		(4.9	)
Net deferred income tax asset	$	16.9		$	8.8

The Company believes that certain offshore cash can be accessed in a tax efficient manner and therefore, as of December 31, 2023, deferred taxes were not provided on approximately $175.7 million of unremitted earnings of foreign subsidiaries that may be remitted to the United States without material tax cost. The Company had approximately $397.4 million and $478.1 million of cumulative foreign earnings as of December 31, 2023 and December 31, 2022, 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, 2023, the Company had approximately $96.4 million of federal net operating loss carryforwards, which are available to reduce future federal tax liabilities. $14.1 million of the federal net operating loss carryforwards expire in 2036 and the remaining $82.3 million is not subject to any time restrictions for future use. As of December 31, 2022, the Company had approximately $96.8 million of federal loss carryforwards, which are available to reduce future federal tax liabilities. $13.5 million of the federal net operating loss carryforward expire in 2036 and the remaining $83.3 million is not subject to any time restrictions for future use. However, utilization of the 2023 and 2022 indefinite lived loss carryforwards is limited annually to 80% of adjusted taxable income. The carryforward is offset by a valuation allowance as of December 31, 2023 and 2022.

As of December 31, 2023 and 2022, the Company had approximately $43.2 million and $26.8 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 is offset by a full valuation allowance as of December 31, 2023 and 2022.

As of December 31, 2023 and 2022, the Company had approximately $616.1 million and $651.9 million, respectively, of state net operating loss carryforwards, which are available to reduce future state tax liabilities. As of December 31, 2023, these state net operating loss carryforwards expire at various times through 2043, respectively. The carryforward is offset by a full valuation allowance as of December 31, 2023 and 2022.

As of December 31, 2023 and 2022, the Company had approximately $212.4 million and $263.5 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 $48.8 million is offset by a valuation allowance as of December 31, 2023 and $163.7 million as of December 31, 2022.

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:

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, 2023, the Company believes that it is more likely than not that the tax positions taken will be sustained upon the resolution of 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, 2023, 2022 and 2021, the Company recorded an increase (decrease) to the gross unrecognized tax benefits including interest and penalties of $0.2 million, $(11.0) million and $(2.1) million, respectively, of which $0.2 million, $(1.7) million and $(0.4) million, respectively, are a result of the net reductions to interest and penalties. Interest and penalties are recognized as a component of income tax expense.

A reconciliation of the beginning and ending amount of unrecognized tax benefits excluding interest and penalties as of December 31, 2023, 2022 and 2021 are summarized as follows:


	2023			2022			2021
Balance at beginning of year	$	9.1		$	18.4		$	20.1
Additions for tax positions of current year		0.1			0.1			0.1
Additions for tax positions of prior years		0.1			3.6			—
Reductions for tax positions of prior years		—			(11.0	)		(0.2	)
Reductions based on settlements with tax authorities		—			—			(0.2	)
Reductions for lapse of statute of limitations		(0.2	)		(2.0	)		(1.4	)
Balance at end of year	$	9.1		$	9.1		$	18.4

As of December 31, 2023, 2022 and 2021, the Company recorded interest and penalties of $1.4 million, $1.2 million and $2.9 million, respectively.

Approximately $4.5 million, $4.7 million and $14.0 million of the Company’s unrecognized tax benefits as of December 31, 2023, 2022 and 2021, 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.