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Income Taxes
6 Months Ended
Jun. 30, 2020
Income Tax Disclosure [Abstract]  
Income Taxes Income Taxes
The provision for income taxes for the three months ended June 30, 2020 and 2019 was an expense of $3.9 million and a benefit of $12.4 million, respectively. The provision for income taxes for the six months ended June 30, 2020 was an expense of $25.6 million compared to a benefit of $12.1 million for the six months ended June 30, 2019.

The effective income tax rate was an expense of 6.6% and a benefit of 13.6% for the three months ended June 30, 2020 and 2019, respectively. The effective income tax rate was an expense of 16.5% for the six months ended June 30, 2020 compared to a benefit of 10.8% for the six months ended June 30, 2019. Both periods include material benefits from intercompany sales of certain intellectual property, as well as movements in unrecognized tax benefits. The changes in effective tax rates are largely attributable to the differences in the relative impacts of these items period over period.

On March 27, 2020, the Coronavirus Aid, Relief, and Economic Security (“CARES”) Act was signed into law in the United States. The CARES Act provides a substantial stimulus and assistance package intended to address the impact of the COVID-19 pandemic. It includes provisions for the deferral of certain taxes and the acceleration of income tax deductions for certain expenses. The Company continues to monitor and record any effects that may result from the CARES Act as well as ongoing government guidance related to COVID-19 that may be issued.

The Company completed intercompany sales of certain intellectual property in both 2020 and 2019. As a result, the Company recorded tax benefits of approximately $28.3 million during the three and six months ended June 30, 2020 and $38.1 million during the three and six months ended June 30, 2019. These benefits represent the value of future tax deductions for amortization of the assets in the acquiring jurisdiction.

In July 2020, the Company completed an intercompany contribution of a significant amount of intellectual property. The Company will not be claiming future tax deductions for amortization of the assets in the acquiring jurisdiction. The Company's intellectual property footprint continues to evolve and may result in tax rate volatility in the future.

The Company had gross unrecognized tax benefits of $114.3 million June 30, 2020 and $102.8 million at December 31, 2019. It is reasonably possible that gross unrecognized tax benefits will decrease by approximately $9.9 million within the next twelve months due to the anticipated closure of audits and the expiration of certain statutes of limitation.