
	2020		2019		2018
Current tax expense:
U.S. federal	$	14,480	$	30,208	$	2,817
State and local	16,360		11,630		6,969
Foreign	62,993		53,105		45,042
Total current	93,833		94,943		54,828
Deferred tax (benefit) expense:
U.S. federal	(7,206)		(16,389)		12,462
State and local	(13,121)		(6,897)		1,258
Foreign	(22,673)		(48,186)		(13,795)
Total deferred	(43,000)		(71,472)		(75)
Total current and deferred	50,833		23,471		54,753
Benefit relating to interest rate swaps used to increase equity	8,257		17,666		3,840
Benefit from stock transactions with employees used to increase equity	56		54		58
Benefit relating to defined-benefit pension adjustments used to increase equity	242		1,258		14
Total tax expense	$	59,388	$	42,449	$	58,665


	December 31,
	2020		2019
Accrued liabilities	$	81,302	$	67,577
Operating leases	51,450		54,860
Loss and credit carryforwards	23,852		14,372
Assets relating to equity compensation	14,981		16,842
Other assets	16,290		20,364
Gross deferred tax assets	187,875		174,015
Property, equipment and leasehold improvements	(9,852)		(15,137)
Intangible assets	(172,723)		(212,498)
Prepaid expenses	(46,105)		(49,221)
Other liabilities	(13,152)		(5,799)
Gross deferred tax liabilities	(241,832)		(282,655)
Valuation allowance	(15,717)		(1,556)
Net deferred tax liabilities	$	(69,674)	$	(110,196)

Net deferred tax assets and net deferred tax liabilities were $103.6 million and $173.2 million as of December 31, 2020, respectively, and $79.6 million and $189.8 million as of December 31, 2019, respectively. These amounts are reported in Other assets and Other liabilities in the Consolidated Balance Sheets. Management has concluded it is more likely than not that the reversal of deferred tax liabilities and results of future operations will generate sufficient taxable income to realize the deferred tax assets, net of the valuation allowance at December 31, 2020.

The valuation allowances of $15.7 million and $1.6 million as of December 31, 2020 and 2019, respectively, primarily related to loss and credit carryovers that are not likely to be realized.

As of December 31, 2020, the Company had state and local tax net operating loss carryforwards of $8.0 million, of which $0.1 million expires within six to fifteen years and $7.9 million expires within sixteen to twenty years. The Company also had state tax credits of $6.0 million, a majority of which will expire in five to six years. As of December 31, 2020, the Company had non-U.S. net operating loss carryforwards of $14.9 million, of which $0.1 million expires over the next 20 years and $14.8 million can be carried forward indefinitely. In addition, the Company also had foreign tax credit carryforwards of $11.9 million, all of which will expire between 2028 and 2030. These amounts have been reduced for associated unrecognized tax benefits, consistent with ASU No. 2013-11, “Income Taxes—Presentation of an Unrecognized Tax Benefit When a Net Operating Loss Carryforward, a Similar Tax Loss, or a Tax Credit Carryforward Exists.”

The items comprising the differences between the U.S. federal statutory income tax rate and the Company’s effective tax rate on income before income taxes for the years ended December 31 are summarized in the table below.


	2020		2019		2018
Statutory tax rate	21.0	%	21.0	%	21.0	%
State income taxes, net of federal benefit	1.7		1.5		—
Effect of non-U.S. operations	(1.8)		2.7		(10.7)
Intercompany sale of intellectual property	(8.7)		(13.8)		—
Change in the reserve for tax contingencies	6.4		4.7		15.7
Law changes	1.8		—		(1.3)
Stock-based compensation expense	(2.8)		(3.9)		(5.3)

Nondeductible meals and entertainment costs	0.3		1.7		2.7
Gains/Losses on divested operations and held-for-sale assets	—		—		12.2
Limitation on executive compensation	1.3		2.4		2.7
Global intangible low-taxed income, net of foreign tax credits	1.4		1.9		0.1
Foreign-derived intangible income	(0.8)		(1.0)		(2.0)

Goodwill	—		—		(3.8)
Other items, net	(1.6)		(1.8)		1.1
Effective tax rate	18.2	%	15.4	%	32.4	%

The Company completed intercompany sales of certain intellectual property in both 2020 and 2019. As a result, the Company recorded net tax benefits of approximately $28.3 million and $38.1 million during 2020 and 2019, respectively. 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’s intellectual property footprint continues to evolve and may result in tax rate volatility in the future.

As of December 31, 2020 and 2019, the Company had gross unrecognized tax benefits of $127.1 million and $102.8 million, respectively. The increase is primarily due to positions taken with respect to intercompany transactions. The gross unrecognized tax benefits at December 31, 2020 related primarily to transfer pricing on intercompany transactions, calculations of taxable earnings and profits and related foreign tax credits, the exclusion of stock-based compensation expense from the Company’s cost sharing agreement, and the ability to realize certain refund claims. It is reasonably possible that gross unrecognized tax benefits will decrease by approximately $9.2 million within the next twelve months due to the anticipated closure of audits and the expiration of certain statutes of limitation.

Included in the balance of gross unrecognized tax benefits at December 31, 2020 are potential benefits of $118.5 million that, if recognized, would reduce our effective tax rate on income from continuing operations. Also included in the balance of gross

The table below is a reconciliation of the beginning and ending amounts of gross unrecognized tax benefits, excluding interest and penalties, for the years ended December 31 (in thousands).


	2020		2019
Beginning balance	$	102,770	$	90,349
Additions based on tax positions related to the current year	20,177		32,072
Additions for tax positions of prior years	14,085		8,564
Reductions for tax positions of prior years	(2,301)		(16,942)
Reductions for expiration of statutes	(8,191)		(7,481)
Settlements	(390)		(3,867)
Change in foreign currency exchange rates	930		75
Ending balance	$	127,080	$	102,770

The Company accrues interest and penalties related to gross unrecognized tax benefits in its income tax provision. As of December 31, 2020 and 2019, the Company had $10.2 million and $8.3 million, respectively, of accrued interest and penalties related to gross unrecognized tax benefits. These amounts are in addition to the gross unrecognized tax benefits disclosed above. The total amount of interest and penalties recognized in the income tax provision during 2020 and 2019 was $2.0 million and $1.7 million, respectively.

The number of years with open statutes of limitation varies depending on the tax jurisdiction. The Company’s statutes are open with respect to the U.S. federal jurisdiction for 2017 and forward, and India for 2004 and forward. For other major taxing jurisdictions, including U.S. states, the United Kingdom, Canada, Japan, France and Ireland, the Company’s statutes vary and are open as far back as 2011.

Under U.S. GAAP, no provision for income taxes that may result from the remittance of earnings held overseas is required if the Company has the ability and intent to indefinitely reinvest such funds overseas. The Company continues to assert its intention to reinvest all accumulated undistributed foreign earnings in its non-U.S. operations, except in instances where the repatriation of those earnings would result in minimal additional tax. Consequently, the Company has not recognized income tax expense that would result from the remittance of those earnings. The accumulated undistributed earnings of non-U.S. subsidiaries were approximately $119.5 million as of December 31, 2020. As a result of the U.S. Tax Cuts and Jobs Act of 2017, the income tax that would be payable if such earnings were not indefinitely invested is estimated to be minimal.