XML 27 R16.htm IDEA: XBRL DOCUMENT v3.10.0.1
INCOME TAXES
9 Months Ended
Sep. 30, 2018
INCOME TAXES [Abstract]  
INCOME TAXES
9.  INCOME TAXES

The Company and its subsidiaries file income tax returns in the U.S. federal jurisdiction and various states and foreign jurisdictions.  The Company is no longer subject to U.S. federal examinations by tax authorities for years before 2015 and for state examinations before 2012.   Regarding foreign subsidiaries, the Company is no longer subject to examination by tax authorities for years before 2008 in Asia and generally 2010 in Europe.

As a result of the expiration of the statutes of limitations for specific jurisdictions, it is reasonably possible that the related unrecognized benefits for tax positions taken regarding previously filed tax returns may change materially from those recorded as liabilities for uncertain tax positions in the Company's consolidated financial statements at September 30, 2018.  The Company's liabilities for uncertain tax positions totaled $28.2 million and $30.4 million at September 30, 2018 and December 31, 2017, respectively, of which $1.1 million and $2.5 million is included in other current liabilities at September 30, 2018 and December 31, 2017, respectively.  These amounts, if recognized, would reduce the Company's effective tax rate.  As of September 30, 2018, approximately $2.5 million of the Company's liabilities for uncertain tax positions were resolved during 2018 by way of expiration of the related statute of limitations.

The Company's policy is to recognize interest and penalties related to uncertain tax positions as a component of the current provision for income taxes.  During the nine months ended September 30, 2018 and 2017, the Company recognized $0.7 million and $0.6 million, respectively, in interest and penalties in the consolidated statements of operations.  During the three and nine months ended September 30, 2018, the Company recognized a benefit of $0.3 million and $0.7 million, respectively, for the reversal of such interest and penalties, relating to the expiration of statutes of limitations and settlement of the acquired liability for uncertain tax positions.  There were no reversals of interest or penalties in the three or nine months ended September 30, 2017.  The Company has approximately $3.1 million and $3.2 million accrued for the payment of interest and penalties at September 30, 2018 and December 31, 2017, respectively, which is included in both income taxes payable and liability for uncertain tax positions in the consolidated balance sheets.

Tax Reform

The Tax Cuts and Jobs Act (the "Act") was enacted on December 22, 2017.  The Act reduces the U.S. federal corporate tax rate from 35% to 21%, requires companies to pay a one-time transition tax on earnings of certain foreign subsidiaries that were previously tax deferred and creates new taxes on certain foreign sourced earnings.  At December 31, 2017, we had not completed our accounting for the tax effects of enactment of the Act; however, we had made a reasonable estimate of the effects on our existing deferred tax balances and the one-time transition tax in which we recognized a provisional amount of $18.1 million, which was included as a component of income tax expense from continuing operations.  During the nine months ended September 30, 2018, the Company has made measurement-period adjustments related to foreign earnings and profits computations and foreign income tax calculations for the Company's non-U.S. subsidiaries.  The Company's measurement-period adjustment reduced its estimate of the deemed repatriation tax by $2.6 million, resulting in the reduction of the Company's provisional estimate from $18.1 million to $15.5 million.  The Company plans to pay the tax in installments in accordance with the Act. The Company's estimates of the effects of the Act were calculated using currently available information; however, the Company is continuing to evaluate the underlying documentation and revisions to the current calculation may occur.

Effective January 1, 2018, the Act subjects a U.S. shareholder to current tax on global intangible low-taxed income (GILTI) earned by certain foreign subsidiaries.  The Company has elected an accounting policy to provide for the tax expense related to the GILTI in the period the tax is incurred.