Income Taxes

3 Months Ended

Mar. 31, 2022

Income Tax Disclosure [Abstract]

Income Taxes

10. Income Taxes

Our income tax provision and the respective effective income tax rates are as follows (in millions, except for income tax rates):

	For the Three Months Ended March 31,
	2022			2021
Income tax provision	$	6.4		$	8.8
Effective income tax rate	19.5		%	31.8		%

Our provision for income taxes for the three months ended March 31, 2022 includes a discrete income tax benefit of $1.2 million, net which relates to a tax benefit of $4.1 million for the remeasurement of an uncertain tax position, a tax expense of $2.0 million for changes related to our state apportionment factors and state net operating loss positions, and a tax expense of $0.8 million related to other worldwide adjustments. For the three months ended March 31, 2021, our provision for income taxes included a discrete income tax benefit of $1.2 million, net of which $1.6 million related to a tax adjustment for the final purchase price allocation on the sale of the MultiService payment solutions business ("MSTS").

Our income tax provisions for the three months ended March 31, 2022 and 2021 were calculated based on the estimated annual effective income tax rates for the 2022 and 2021 years, respectively. The actual effective income tax rate for the 2022 year may be materially different for several reasons including differences between estimated versus actual results and the geographic tax jurisdictions in which the results are earned.

We have various tax returns under examination both in the U.S. and foreign jurisdictions. The most material of these are in Denmark for the 2013 - 2019 tax years, South Korea for the 2011 - 2014 tax years, and the U.S. for the 2019 tax year. One of our subsidiaries in Denmark has been under audit for its 2013 - 2015 tax years since 2018 and was notified in March 2021 that its 2016 - 2019 tax years were also under examination. Through the three months ended March 31, 2022, we have received final tax assessments for the 2013 and 2014 tax years that were immaterial and a proposed tax assessment for the 2015 tax year of approximately $14.3 million (DKK 96.1 million). In April 2022, we received a proposed tax assessment for the 2016 and 2017 tax years of approximately $19.9 million (DKK 133.8 million) and $23.1 million (DKK 155.5 million), respectively. We believe these assessments are without merit and are vigorously defending against the actions. We have not yet received any proposed assessments related to the 2018 - 2019 tax years, which could be materially larger than the previous assessments if a similar methodology is applied.

In March 2022, we received a proposed settlement for the 2011-2014 tax years of the Korean branch of one of our subsidiaries related to income tax assessment notices received in 2017 totaling $9.3 million (KRW 11.3 billion) and revised in 2021 to $8.8 million (KRW 10.6 billion). The proposed settlement reduces the total South Korean assessment for the 2011 - 2014 tax years to approximately $1.6 million (KRW 2.0 billion), including tax, interest, and penalties. We agreed to the settlement on April 25, 2022 and anticipate ultimately resolving the audit in 2022.

The U.S. IRS examination for our 2019 tax year began in February 2022 and we are currently responding to information requests. In March 2022, we accepted and agreed to the remaining notices of proposed assessment received from the IRS in December 2021 for our 2017 and 2018 tax years. These assessments did not have a material impact on our income tax or financial results and no additional proposed assessments are expected for the 2017 and 2018 years.

An unfavorable resolution of one or more of the above matters could have a material adverse effect on our operating results or cash flows in the quarter or year in which the adjustments are recorded, or the tax is due or paid. As examinations are still in process or have not yet reached the final stages of the appeals process, the timing of the ultimate resolution or payments that may be required cannot be determined at this time.