Income Taxes	6 Months Ended
Jun. 24, 2016
Income Taxes
Income Taxes	(11) Income Taxes After adjusting for the impact of loss attributable to noncontrolling interests, the effective tax rate on the loss attributable to CH2M for the six months ended June 24, 2016 was 51.5% compared to 32.1% on the profit for the same period in the prior year and for the loss attributable to the three months ended June 24, 2016 was 46.4% compared to 36.4% for the profit for the same period in the prior year. The effective tax rate attributable to CH2M for the three and six months ended June 24, 2016 was higher compared to the same periods in the prior year primarily due to the favorable impacts associated with the release of the valuation allowances for net operating losses due to the implementation of a new transfer pricing policy. Our effective tax rate continues to be negatively impacted by the effect of non-deductible foreign net operating losses and the disallowed portions of meals and entertainment expenses. Estimated undistributed earnings of our foreign subsidiaries amounted to approximately $455.6 million and $341.8 million at June 24, 2016 and December 25, 2015, respectively. These earnings are considered to be permanently reinvested. Accordingly, no provision for U.S. federal and state income taxes or foreign withholding taxes has been made. Determining the tax liability that would arise if these earnings were repatriated is not practical. As of June 24, 2016 and December 25, 2015, we had $47.3 million and $38.5 million, respectively, recorded as a liability for uncertain tax positions. We recognize interest and penalties related to unrecognized tax benefits in income tax expense. Included in the amounts discussed above are approximately $3.4 million and $3.0 million of accrued interest and penalties related to uncertain tax positions, as of June 24, 2016 and December 25, 2015, respectively. We file income tax returns in the U.S. federal jurisdiction and various state and foreign jurisdictions. In the normal course of business, we are subject to examination by taxing authorities throughout the world, including such major jurisdictions as the United States, United Kingdom and Canada. With few exceptions, we are no longer subject to U.S. federal, state and local or non-U.S. income tax examinations by tax authorities in major tax jurisdictions for years before 2009.

(11) Income Taxes

After adjusting for the impact of loss attributable to noncontrolling interests, the effective tax rate on the loss attributable to CH2M for the six months ended June 24, 2016 was 51.5% compared to 32.1% on the profit for the same period in the prior year and for the loss attributable to the three months ended June 24, 2016 was 46.4% compared to 36.4% for the profit for the same period in the prior year. The effective tax rate attributable to CH2M for the three and six months ended June 24, 2016 was higher compared to the same periods in the prior year primarily due to the favorable impacts associated with the release of the valuation allowances for net operating losses due to the implementation of a new transfer pricing policy. Our effective tax rate continues to be negatively impacted by the effect of non-deductible foreign net operating losses and the disallowed portions of meals and entertainment expenses.

Estimated undistributed earnings of our foreign subsidiaries amounted to approximately $455.6 million and $341.8 million at June 24, 2016 and December 25, 2015, respectively. These earnings are considered to be permanently reinvested. Accordingly, no provision for U.S. federal and state income taxes or foreign withholding taxes has been made. Determining the tax liability that would arise if these earnings were repatriated is not practical.

As of June 24, 2016 and December 25, 2015, we had $47.3 million and $38.5 million, respectively, recorded as a liability for uncertain tax positions. We recognize interest and penalties related to unrecognized tax benefits in income tax expense. Included in the amounts discussed above are approximately $3.4 million and $3.0 million of accrued interest and penalties related to uncertain tax positions, as of June 24, 2016 and December 25, 2015, respectively.

We file income tax returns in the U.S. federal jurisdiction and various state and foreign jurisdictions. In the normal course of business, we are subject to examination by taxing authorities throughout the world, including such major jurisdictions as the United States, United Kingdom and Canada. With few exceptions, we are no longer subject to U.S. federal, state and local or non-U.S. income tax examinations by tax authorities in major tax jurisdictions for years before 2009.