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Income Taxes
12 Months Ended
Dec. 31, 2014
Income Taxes  
Income Taxes

 

Note 4—Income Taxes

 

The components of income before income taxes and the provision for income taxes are as follows:

 

 

 

Year Ended December 31,

 

 

 

2014

 

2013

 

2012

 

 

 

 

 

 

 

 

 

Income before income taxes:

 

 

 

 

 

 

 

United States 

 

$

161.4

 

$

152.8

 

$

145.8

 

Foreign 

 

811.1

 

693.8

 

633.0

 

 

 

$

972.5

 

$

846.6

 

$

778.8

 

 

 

 

 

 

 

 

 

Current tax provision:

 

 

 

 

 

 

 

United States 

 

$

63.7

 

$

47.5

 

$

54.6

 

Foreign 

 

183.1

 

162.3

 

163.1

 

 

 

246.8

 

209.8

 

217.7

 

 

 

 

 

 

 

 

 

Deferred tax provision (benefit):

 

 

 

 

 

 

 

United States 

 

(0.7

)

(0.1

)

7.7

 

Foreign 

 

11.2

 

(1.8

)

(6.1

)

 

 

10.5

 

(1.9

)

1.6

 

Total provision for income taxes 

 

$

257.3

 

$

207.9

 

$

219.3

 

 

At December 31, 2014, the Company had $60.3, $16.9 and $4.4 of foreign tax loss and credit carryforwards, U.S. federal loss carryforwards, and U.S. state tax loss and credit carryforwards net of federal benefit, respectively, of which $28.8, $16.9 and $0.1, respectively, will either expire or be refunded at various dates through 2029 and the balance can be carried forward indefinitely.

 

A valuation allowance of $15.5 and $19.4 at December 31, 2014 and 2013, respectively, has been recorded which relates to the foreign net operating loss carryforwards and U.S. state tax credits.  The net change in the valuation allowance for deferred tax assets was a decrease of $3.9 and an increase of $1.5 in 2014 and 2013, respectively, which was related to foreign net operating loss and foreign and U.S. state credit carryforwards.

 

Differences between the U.S. statutory federal tax rate and the Company’s effective income tax rate are analyzed below:

 

 

 

Year Ended December 31,

 

 

 

2014

 

2013

 

2012

 

 

 

 

 

 

 

 

 

U.S. statutory federal tax rate

 

35.0

%

35.0

%

35.0

%

State and local taxes

 

0.4

 

0.6

 

0.6

 

Foreign earnings and dividends taxed at different rates

 

(8.3

)

(9.4

)

(7.9

)

Valuation allowance

 

(0.4

)

0.2

 

(0.2

)

Tax impact of the delay in American Taxpayer Relief Act

 

 

(1.3

)

1.5

 

Other

 

(0.2

)

(0.5

)

(0.8

)

Effective tax rate

 

26.5

%

24.6

%

28.2

%

 

The 2013 tax rate reflects a decrease in tax expense and the 2012 tax rate reflects an increase in tax expense of $11.3, or $0.03 per diluted common share, resulting from the delay, by the U.S. government, in the reinstatement of certain federal income tax provisions for the year 2012 relating primarily to research and development credits and certain U.S. taxes on foreign income that are part of the tax provisions within the American Taxpayer Relief Act.  Such tax provisions were reinstated on January 2, 2013 with retroactive effect to 2012.  Under U.S. GAAP, the benefit to the Company of $11.3 relating to the 2012 tax year was recorded as a benefit in the first quarter of 2013 at the date of reinstatement; as such, between the fourth quarter of 2012 and the first quarter of 2013, there is no net impact on the Company from an income statement perspective.  The 2013 tax rate also reflects a reduction in tax expense of $3.6, or $0.01 per diluted common share, for tax reserve adjustments relating to the completion of the audits of certain of the Company’s prior year tax returns.  Excluding these impacts as well as the net impact of the acquisition-related expenses, the Company’s effective tax rate for 2014, 2013 and 2012 was 26.5%, 26.3% and 26.7%, respectively.

 

The Company’s deferred tax assets and liabilities included in Other current assets, Intangibles and other long-term assets and in Accrued pension benefit obligations and other long-term liabilities in the accompanying Consolidated Balance Sheets, excluding the valuation allowance, comprised the following:

 

 

 

December 31,

 

 

 

2014

 

2013

 

Deferred tax assets relating to:

 

 

 

 

 

Accrued liabilities and reserves

 

$

27.3 

 

$

25.3 

 

Operating loss and tax credit carryforwards

 

26.2 

 

19.6 

 

Pensions, net

 

61.1 

 

35.2 

 

Inventory reserves

 

22.6 

 

18.8 

 

Employee benefits

 

35.6 

 

32.0 

 

 

 

$

172.8 

 

$

130.9 

 

 

 

 

 

 

 

Deferred tax liabilities relating to:

 

 

 

 

 

Goodwill

 

$

129.4 

 

$

108.5 

 

Depreciation and amortization

 

36.1 

 

4.2 

 

Contingent consideration

 

6.6 

 

6.6 

 

 

 

$

172.1 

 

$

119.3 

 

 

At December 31, 2014 and 2013, the amount of the liability for unrecognized tax benefits, including penalties and interest, which if recognized would impact the effective tax rate, was approximately $19.2 and $14.9, respectively.

 

A tabular reconciliation of the gross amounts of unrecognized tax benefits excluding interest and penalties at the beginning and end of the year for 2014, 2013 and 2012 are as follows:

 

 

 

2014

 

2013

 

2012

 

Unrecognized tax benefits as of January 1

 

$

24.8

 

$

26.4

 

$

20.2

 

Gross increases and gross decreases for tax positions in prior periods

 

2.2

 

1.4

 

11.3

 

Gross increases - current period tax position

 

2.6

 

2.4

 

1.5

 

Settlements

 

(0.5

)

 

(3.1

)

Lapse of statute of limitations

 

(1.4

)

(5.4

)

(3.5

)

Unrecognized tax benefits as of December 31

 

$

27.7

 

$

24.8

 

$

26.4

 

 

The Company includes estimated interest and penalties related to unrecognized tax benefits in the provision for income taxes. During the years ended December 31, 2014, 2013 and 2012, the provision for income taxes included a net expense (benefit) of $0.9, $0.2 and $(0.3), respectively, in estimated interest and penalties.  As of December 31, 2014, 2013 and 2012, the liability for unrecognized tax benefits included $4.5, $3.0 and $2.8, respectively, for tax-related interest and penalties.

 

The Company operates in the U.S. and numerous foreign taxable jurisdictions, and at any point in time has numerous audits underway at various stages of completion. With few exceptions, the Company is subject to income tax examinations by tax authorities for the years 2011 and after. The Company is generally not able to precisely estimate the ultimate settlement amounts or timing until the close of an audit.  The Company evaluates its tax positions and establishes liabilities for uncertain tax positions that may be challenged by local authorities and may not be fully sustained, despite the Company’s belief that the underlying tax positions are fully supportable. As of December 31, 2014, the amount of the liability for unrecognized tax benefits, which if recognized would impact the effective tax rate, was $19.2 the majority of which is included in Accrued pension benefit obligations and other long-term liabilities in the accompanying Consolidated Balance Sheets. Unrecognized tax benefits are reviewed on an ongoing basis and are adjusted for changing facts and circumstances, including progress of tax audits and closing of statute of limitations.  Based on information currently available, management anticipates that over the next twelve month period, audit activity could be completed and statutes of limitations may close relating to existing unrecognized tax benefits of $3.3.