7. Income Taxes

The following table presents components of income tax expense/(benefit) for the three and six months ending June 30, 2014 and 2013:

	Three months ended June 30,		Six months ended June 30,
(in thousands)	2014	2013	2014	2013

Income tax based on income from continuing operations, at estimated tax rates of 36.5% and 39.0%, respectively	$6,368	($3,616)	$12,999	$3,310
Provision for change in estimated tax rates	278	888	-	-
Income tax before discrete items	6,646	(2,728)	12,999	3,310

Discrete tax expense/(benefit):
Provision for/adjustment to beginning of year valuation allowances	437	-	437	-
Provision for/resolution of tax audits and contingencies, net	99	425	979	425
Adjustments to prior period tax liabilities	30	(126)	254	84
Repatriation of non-U.S. prior years' earnings	-	186	-	186
Other discrete tax adjustments, net	4	-	4	-
Total income tax expense/(benefit)	$7,216	($2,243)	$14,673	$4,005

The second quarter estimated effective tax rate on continuing operations was 36.5 percent in 2014, as compared to 39.0 percent for the same period in 2013. The change in the estimated effective tax rate was primarily attributable to the amount and distribution of income and loss among the countries in which we operate.

At June 30, 2014 the Company reported a deferred tax liability of $0.3 million on $3.6 million of prior year non-U.S. earnings that have been targeted for future repatriation to the U.S. The Company records the residual U.S. and foreign taxes on certain amounts of current foreign earnings that have been targeted for repatriation to the U.S. As a result, such amounts are not considered to be permanently reinvested, and the Company accrued for the residual taxes on these earnings to the extent they cannot be repatriated in a tax-free manner.

We conduct business globally and, as a result, the Company or one or more of our subsidiaries files 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 major jurisdictions such as the United States, Brazil, Canada, China, France, Germany, Italy, Mexico, and Switzerland. The open tax years in these jurisdictions range from 2000 to 2013. We are currently under audit in the U.S. and in other non-U.S. tax jurisdictions, including but not limited to Canada, Germany and Italy.

It is reasonably possible that over the next twelve months the amount of the liability on uncertain tax positions may change within a range of a net increase of $0 million to a net decrease of $9.8 million, from the reevaluation of uncertain tax positions arising in examinations, in appeals, or in the courts, or from the closure of tax statutes. Not included in the range is $24.0 million of tax benefits in Germany related to a 1999 reorganization that have been challenged by the German tax authorities in the course of an audit, of which $18.4 million would have a direct impact on our Statements of Income if resolved unfavorably. In 2008 the German Federal Tax Court (FTC) denied tax benefits to other taxpayers in a case involving German tax laws relevant to our reorganization. One of these cases involved a non-German party, and in the ruling in that case, the FTC acknowledged that the German law in question may be violative of European Union (EU) principles and referred the issue to the European Court of Justice (ECJ) for its determination on this issue. In September 2009, the ECJ issued an opinion in this case that is generally favorable to the other taxpayer and referred the case back to the FTC for further consideration. In May 2010 the FTC released its decision, in which it resolved certain tax issues that may be relevant to our audit and remanded the case to a lower court for further development. In 2012, the lower court decided in favor of the taxpayer and the government appealed the findings to the FTC. On July 2, 2014, The FTC conducted a hearing in the aforementioned case involving the other taxpayer and a decision is expected later in the year. Although we were required to pay tax and interest of approximately $16.3 million to the German tax authorities in order to continue to pursue the position, when taking into consideration the ECJ decision, the May 2010 FTC decision and the lower court decision, we believe that it is more likely than not that the relevant German law is violative of EU principles and, accordingly, we have not accrued tax expense on this matter. As we continue to monitor developments and consider the outcome of the July 2, 2014 hearing, it may become necessary for us to accrue tax expense and related interest.