Income Taxes

6 Months Ended

Jun. 30, 2022

Income Tax Disclosure [Abstract]

Income Taxes

5.Income Taxes

The Company recorded income tax expense of $13.7 million, or 32.3% of pre-tax income, for the three months ended June 30, 2022, compared to an income tax benefit of $21.9 million for the three months ended June 30, 2021. Results for the three months ended June 30, 2022 were unfavorably impacted by $1.5 million of net discrete items. Results for the three months ended June 30, 2021 were impacted by a $69.9 million discrete tax benefit for the implementation of a plan to make certain tax accounting method changes and change the timing of certain deductible payments, allowing the Company to carry back the net operating loss to prior tax years with higher federal statutory tax rates.

The Company recorded income tax expense of $33.9 million, or 55.4% of pre-tax income, for the six months ended June 30, 2022, compared to $11.3 million, or 3.5% of pre-tax income, for the six months ended June 30, 2021. Results for the six months ended June 30, 2022 were unfavorably impacted by $16.9 million of net discrete tax items, including a charge of $18.1 million related to taxes on previous income as the Company revised its interpretation of certain foreign anti-hybrid tax legislation based upon comments from the corresponding tax authorities. Results for the six months ended June 30, 2021 were favorably impacted by the $69.9 million discrete tax benefit.

The Company’s liability for gross unrecognized tax benefits, excluding related interest and penalties, was $83.4 million and $41.5 million as of June 30, 2022 and December 31, 2021, respectively. Included in the Company’s June 30, 2022 liability for gross unrecognized tax benefits is a $19.2 million reserve related to foreign anti-hybrid legislation and a $22.3 million U.S. federal reserve for a temporary deferred position. As of June 30, 2022, net unrecognized tax benefits, excluding interest and penalties, of $45.3 million would affect the Company’s net income if recognized.

The Company recognizes accrued interest and penalties, if any, related to unrecognized tax benefits in the “Provision for income taxes” in the Condensed Consolidated Statements of Income. During the six months ended June 30, 2022 and 2021, the Company recognized expense of $0.7 million and $0.9 million, respectively, related to interest and penalties. At June 30, 2022, the Company had accruals for the payment of interest and penalties of $4.2 million. During the next twelve months, it is reasonably possible that federal, state and foreign tax audit resolutions could reduce net unrecognized tax benefits by approximately $5.3 million because the Company’s tax positions are sustained on audit, the Company agrees to their disallowance or the statutes of limitations close.