Income Taxes (Tables)

12 Months Ended

Dec. 31, 2016

U.S. and foreign income before income taxes consist of the following (in millions):

The income tax provision (benefit) related to income before income taxes consists of the following components (in millions):



	2016			2015			2014
Current:
U.S. federal statutory tax	$	7.5		$	(9.9	)	$	13.9
State	0.8			0.7			2.5
Foreign	30.4			27.0			23.5
	38.7			17.8			39.9
Deferred:
U.S. federal statutory tax	(29.3		)	4.6			10.7
State	(4.2		)	3.0			2.7
Foreign	(2.5		)	(2.3		)	(2.6		)
	(36.0		)	5.3			10.8
Non-current tax expense (income)	13.0			24.1			2.9
	$	15.7		$	47.2		$	53.6

A reconciliation of the U.S. federal statutory income tax rate to our effective income tax rate is as follows:



	2016		2015		2014
U.S. federal statutory tax rate	35.0	%	35.0	%	35.0	%
Foreign earnings, net of foreign taxes	(42.4	)	(28.3	)	(18.2	)
State income taxes, net of U.S. federal income tax benefit	(1.5	)	1.1		1.3
U.S. tax on deemed dividends	1.3		1.7		1.2
Sale of subsidiary	3.8		—		—
Uncertain tax positions	9.2		10.3		1.1
Other permanent differences	5.6		1.9		(0.9	)
Effective income tax rate	11.0	%	21.7	%	19.5	%

The temporary differences which comprise our net deferred tax liabilities are as follows (in millions):



	As of December 31,
	2016			2015
Gross Deferred Tax Assets:
Bad debt reserve	$	4.5		$	5.0
Net operating loss	38.6			13.0
Accrued and other share-based compensation	26.2			20.6
Accrued expenses	5.0			—
U.S. foreign income tax credits	7.8			5.3
Other income tax credits	0.2			0.7
Customer deposits	6.3			5.7
Installment sale	—			6.7
Cash flow hedges	4.6			0.8
Unrealized foreign exchange	—			2.7
Total gross deferred tax assets	93.2			60.5
Less: Valuation allowance	7.1			2.9
Gross deferred tax assets, net of valuation allowance	86.1			57.6
Deferred Tax Liabilities:
Depreciation	(8.5		)	(20.8		)
Goodwill and intangible assets	(56.1		)	(56.2		)
Unrealized foreign exchange	(8.0		)	—
Prepaid expenses, deductible for tax purposes	(5.8		)	(4.4		)
Accrued expenses	—			(2.5		)
Unrealized derivatives	(2.4		)	(5.1		)
Other	(0.7		)	—
Total gross deferred tax liabilities	(81.5		)	(89.0		)
Net deferred tax liability	$	—		$	(31.4	)
Net deferred tax asset	4.6			—
Reported on the consolidated balance sheets as:
Identifiable intangible and other non-current assets for deferred tax assets, non-current	$	20.6		$	5.2

Non-current income tax liabilities, net for deferred tax liabilities, non-current	$	16.0		$	36.6

This deferred tax asset expires as follows (in millions):

The following is a tabular reconciliation of the total amounts of unrecognized income tax benefits for the year (in millions):



	2016			2015			2014
Unrecognized Tax Liabilities – opening balance	$	46.7		$	24.3		$	26.5
Gross increases – tax positions in prior period	18.0			9.2			—
Gross decreases – tax positions in prior period	(15.4		)	(4.8		)	(2.8		)
Gross increases – tax positions in current period	11.3			20.9			6.6
Gross decreases – tax positions in current period	—			—			—
Settlements	—			—			(3.6		)
Lapse of statute of limitations	(2.8		)	(2.9		)	(2.4		)
Unrecognized Tax Liabilities – ending balance	$	57.8		$	46.7		$	24.3

The following table summarizes these open tax years by jurisdiction with major uncertain tax positions:



	Open Tax Year
Jurisdiction	Examination in progress	Examination not yet initiated
United States	2011 - 2012	2013 - 2016
Korea	2011 - 2014	2015 - 2016
Singapore	None	2011 - 2016
United Kingdom	2014	2012 - 2016
Brazil	None	2011 - 2016
Chile	None	2014 - 2016
Denmark	None	2012 - 2016