INCOME TAXES

12 Months Ended

Dec. 31, 2019

The components of income (loss) before income taxes were as follows:


	Year Ended December 31,
(in millions)	2019		2018		2017

United States	$	(109.8)	$	(279.6)	$	(145.0)
Foreign	455.2		(678.8)		(1,458.5)
	$	345.4	$	(958.4)	$	(1,603.5)

The components of the provision (benefit) for income taxes from operations were as follows:


	Year Ended December 31,
(in millions)	2019		2018		2017

Current:
U.S. federal	$	(11.2)	$	9.8	$	1.7
U.S. state	1.5		3.2		5.9
Foreign	129.4		101.5		83.0
Total	$	119.7	$	114.5	$	90.6

Deferred:
U.S. federal	$	(2.0)	$	46.4	$	2.8
U.S. state	1.8		(3.0)		11.4
Foreign	(37.2)		(105.4)		(158.0)
Total	$	(37.4)	$	(62.0)	$	(143.8)

	$	82.3	$	52.5	$	(53.2)

The reconciliation of the U.S. federal statutory tax rate to the effective rate were as follows:


	Year Ended December 31,
	2019		2018		2017

Statutory U.S. federal income tax rate	21.0	%	21.0	%	35.0	%
Effect of:
State income taxes, net of federal benefit	0.7		(0.2)		(0.1)
Federal benefit of R&D and foreign tax credits	(2.0)		1.0		2.8
Tax effect of international operations	0.4		1.8		3.6
Global Intangible Low Taxed Income (GILTI)	3.7		(1.1)		—
Net effect of tax audit activity	0.4		(1.0)		(0.6)
Tax effect of enacted statutory rate changes on Non-U.S. jurisdictions	0.1		0.3		(0.2)
Federal tax on unremitted earnings of certain foreign subsidiaries	0.1		(0.1)		—
Valuation allowance adjustments	(1.3)		(5.7)		(0.7)
U.S. tax reform - net impacts	—		0.4		(1.2)
Tax effect of impairment of goodwill and intangibles	(0.2)		(22.1)		(37.4)
Other	0.9		0.2		2.1

Effective income tax rate on operations	23.8	%	(5.5	%)	3.3	%

The tax effect of significant temporary differences giving rise to deferred tax assets and liabilities were as follows:


	Year Ended December 31,
	2019						2018
(in millions)	Deferred Tax Asset		Deferred Tax Liability		Deferred Tax Asset		Deferred Tax Liability

Commission and bonus accrual	$	10.6	$	—	$	4.5	$	—
Employee benefit accruals	55.9		—		56.8		—
Inventory	15.3		—		13.9		—
Identifiable intangible assets	—		630.7		—		686.0
Insurance premium accruals	3.0		—		3.2		—
Miscellaneous accruals	21.3		—		19.2		—
Other	—		2.2		3.0		—
Unrealized losses included in AOCI	46.0		—		24.4		—
Property, plant and equipment	—		49.6		—		56.1
Lease right-of-use asset	—		38.8		—		—
Lease right-of-use liability	39.7		—		—		—
Product warranty accruals	1.5		—		1.5		—
Foreign tax credit and R&D carryforward	73.5		—		78.8		—
Restructuring and other cost accruals	3.8		—		3.1		—
Sales and marketing accrual	6.2		—		5.3		—
Taxes on unremitted earnings of foreign subsidiaries	—		3.5		—		3.2
Tax loss carryforwards and other tax attributes	268.6		—		285.8		—
Subtotal	$	545.4	$	724.8	$	499.5	$	745.3
Valuation allowances	(288.0)		—		(288.4)		—
Total	$	257.4	$	724.8	$	211.1	$	745.3

Deferred tax assets and liabilities are included in the following Consolidated Balance Sheets line items at December 31 were as follows:


(in millions)	2019		2018

Assets
Other noncurrent assets, net	$	12.2	$	18.6
Liabilities
Deferred income taxes	$	479.6	$	552.8

The Company has $71.2 million of foreign tax credit carryforwards at December 31, 2019, of which $29.1 million will expire in 2024, $38.9 million will expire in 2025, $1.5 million will expire in 2028, and $1.7 million will expire in 2029.

The Company has tax loss carryforwards related to certain foreign and domestic subsidiaries of approximately $1,303.2 million at December 31, 2019, of which $1,045.3 million expires at various times through 2039 and $257.9 million may be carried forward indefinitely. Included in deferred income tax assets at December 31, 2019 are tax benefits totaling $239.3 million, before valuation allowances, for the tax loss carryforwards. In addition the Company has recorded a deferred tax asset of $29.3 million, related to tax attributes.

The Company has recorded $217.2 million of valuation allowance to offset the tax benefit of net operating losses, $56.2 million to offset the tax benefit of foreign tax credits, and $14.6 million of valuation allowance for other deferred tax assets. The Company has recorded these valuation allowances due to the uncertainty that these assets can be realized in the future.

The Company has provided $3.5 million of withholding taxes on certain undistributed earnings of its foreign subsidiaries that the Company anticipates will be repatriated.

Tax Contingencies

The total amount of gross unrecognized tax benefits at December 31, 2019 is approximately $26.0 million, of this total, approximately $24.4 million represents the amount of unrecognized tax benefits that, if recognized, would affect the effective income tax rate. It is reasonably possible that certain amounts of unrecognized tax benefits will significantly increase or decrease within twelve months of the reporting date of the Company’s consolidated financial statements. Final settlement and resolution of outstanding tax matters in various jurisdictions during the next twelve months could include unrecognized tax benefits of approximately $5.8 million. Of this approximately $5.3 million represents the amount of unrecognized tax benefits that, if recognized would affect the effective income tax rate.

The total amount of accrued interest and penalties were $2.5 million and $4.1 million at December 31, 2019 and 2018, respectively. The Company has consistently classified interest and penalties recognized in its consolidated financial statements as income taxes based on the accounting policy election of the Company. During the years ended December 31, 2018 and 2017, the Company recognized income tax expense of $0.6 million and $0.5 million respectively, related to interest and penalties. During the year ended December 31, 2019, the Company recognized income tax benefit of $1.5 million, related to interest and penalties.

The Company is subject to U.S. federal income tax as well as income tax of multiple state and foreign jurisdictions. The significant jurisdictions include the U.S., Germany, Sweden and Switzerland. The Company has substantially concluded all U.S. federal income tax matters for years through 2011. The Company is currently under audit for the tax years 2012 and 2013 and 2015 and 2016. For further information on the Internal Revenue Service (“IRS”) Audit, see Note 20, Commitments and Contingencies. The tax years 2014 through 2018 are subject to future potential tax audit adjustments. The Company has concluded audits in Germany through the tax year 2014 and is currently under audit for the years 2015 through 2017. The taxable years that remain open for Sweden are 2013 through 2018. For information related to Sweden, see Note 20, Commitments and Contingencies. The taxable years that remain open for Switzerland are 2009 through 2018.

The activity recorded for unrecognized tax benefits were as follows:


(in millions)	2019		2018		2017

Unrecognized tax benefits at beginning of period	$	27.8	$	21.0	$	10.8
Gross change for prior period positions	(0.4)		7.5		8.6
Gross change for current year positions	0.3		0.3		0.3
Decrease due to settlements and payments	(3.9)		(0.3)		—
Decrease due to statute expirations	—		(0.1)		—
Increase due to effect of foreign currency translation	—		—		1.3
Decrease due to effect from foreign currency translation	(0.3)		(0.6)		—

Unrecognized tax benefits at end of period	$	23.5	$	27.8	$	21.0

U.S. Federal Legislative Changes

On December 22, 2017, the Tax Cuts and Jobs Act (the "Act" or "U.S. tax reform") was enacted. U.S. tax reform, among other things, reduced the U.S. federal income tax rate to 21% in 2018 from 35%, instituted a dividends received deduction for foreign earnings with a related tax for the deemed repatriation of unremitted foreign earnings and created a new U.S. minimum tax on earnings of foreign subsidiaries. In addition, the SEC staff issued Staff Accounting Bulletin No. 118 (“SAB 118”), which provides guidance on accounting for enactment effects of the Act and provides a measurement period of up to one year from the Act’s enactment date for companies to complete their accounting under Accounting Standards Codification No. 740 “Income Taxes”, (“ASC 740”). In accordance with SAB 118, income tax effects of the Act were refined upon obtaining, preparing, and analyzing additional information during the measurement period. At December 31, 2018 the Company had completed its accounting for the tax effects of the Act.