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Income Taxes
12 Months Ended
Dec. 31, 2016
Income Tax Disclosure [Abstract]  
Income Taxes
INCOME TAXES
Income before income taxes was taxed in the following jurisdictions in each of the years ended December 31:
 
2016
 
2015
 
2014
 
(Dollars in thousands)
Domestic
$
212,987

 
$
222,188

 
$
273,487

Foreign
18,930

 
30,698

 
11,065

Total
$
231,917

 
$
252,886

 
$
284,552


The components of the provision for income taxes were as follows:
 
 
2016
 
2015
 
2014
 
(Dollars in thousands)
Current:
 
 
 
 
 
Federal
$
27,805

 
$
77,777

 
$
51,399

State
(577
)
 
7,972

 
4,487

Foreign
6,327

 
8,002

 
7,519

Current income tax provision
33,555

 
93,751

 
63,405

Deferred:
 
 
 
 
 
Federal
42,964

 
(10,065
)
 
38,879

State
3,445

 
(1,932
)
 
2,958

Foreign
(1,398
)
 
(1,281
)
 
(3,081
)
Deferred income tax provision (benefit)
45,011

 
(13,278
)
 
38,756

 
$
78,566

 
$
80,473

 
$
102,161


The provision for income taxes varied from income taxes computed at the statutory U.S. federal income tax rate as a result of the following:
 
2016
 
2015
 
2014
 
(Dollars in thousands)
Income taxes computed at the statutory
    U.S. federal income tax rate
$
81,171

 
$
88,512

 
$
99,597

State income taxes, net of federal tax benefit
4,264

 
4,903

 
8,165

Tax liabilities (no longer required) required
(408
)
 
2,342

 
815

Valuation allowance
474

 
1,441

 
(3,747
)
Manufacturing exemption
(3,613
)
 
(7,849
)
 
(5,798
)
Tax credit refunds, net
(2,676
)
 
(2,325
)
 
(2,163
)
Foreign earnings taxed at other than 35%
(2,334
)
 
(6,383
)
 
5,957

Deferred tax rate changes
(371
)
 
163

 
(1,327
)
Other
2,059

 
(331
)
 
662

 
$
78,566

 
$
80,473

 
$
102,161

 
 
 
 
 
 
Effective tax rate
33.9
%
 
31.8
%
 
35.9
%


Deferred income taxes reflect the net tax effect of temporary differences between the financial statement carrying amounts of assets and liabilities and their respective tax bases and operating loss and tax credit carryforwards. Significant components of our deferred tax assets and liabilities at December 31 were as follows:
 
2016
 
2015
 
(Dollars in thousands)
Deferred tax assets:
 
 
 
Pension and other postretirement liabilities
$
14,678

 
$
11,000

Rationalization and other accrued liabilities
22,933

 
25,306

Property, plant and equipment
331

 
1,053

AMT and other credit carryforwards
1,449

 
1,733

Net operating loss carryforwards
21,605

 
26,357

Other intangible assets
821

 
1,025

Foreign currency translation
426

 
236

Inventory and related reserves
16,824

 
27,176

Other
3,482

 
5,337

Total deferred tax assets
82,549

 
99,223

Deferred tax liabilities:
 
 
 
Property, plant and equipment
(208,409
)
 
(192,372
)
Pension and other postretirement liabilities
(30,414
)
 
(18,268
)
Other intangible assets
(81,209
)
 
(81,650
)
Foreign currency translation
(22,156
)
 
(21,697
)
Other
(9,292
)
 
(4,200
)
Total deferred tax liabilities
(351,480
)
 
(318,187
)
Valuation allowance
(8,147
)
 
(8,648
)
 
$
(277,078
)
 
$
(227,612
)

At December 31, 2016, the net deferred tax liability in our Consolidated Balance Sheets was comprised of long-term deferred tax assets of $21.3 million and long-term deferred tax liabilities of $298.4 million. At December 31, 2015, the net deferred tax liability in our Consolidated Balance Sheets was comprised of long-term deferred tax assets of $21.1 million and long-term deferred tax liabilities of $248.7 million. Long-term deferred tax assets and long-term deferred tax liabilities were classified as other assets, net and other liabilities, respectively, in our Consolidated Balance Sheets.
The valuation allowance in 2016 includes deferred tax assets of $8.1 million resulting from foreign net operating loss carryforwards, or NOLs. The valuation allowance for deferred tax assets decreased in 2016 by $0.5 million primarily due to a decrease in the valuation allowance related to foreign tax loss carryforwards and state and local tax credits.
At December 31, 2016, we had foreign NOLs of approximately $17.0 million that are available to offset future taxable income. Of that amount, approximately $5.1 million will expire from 2017 to 2027. The remaining portion has no expiration date. At December 31, 2016, we had state tax NOLs of approximately $4.6 million that are available to offset future taxable income and that will expire from 2024 to 2035.
We recognize accrued interest and penalties related to unrecognized taxes as additional income tax expense. At December 31, 2016 and 2015, we had $3.8 million and $4.3 million, respectively, accrued for potential interest and penalties.
The total amount of unrecognized tax benefits recorded in other liabilities as of December 31, 2016 and 2015 were $36.1 million and $32.8 million, respectively, excluding associated tax assets and including the federal tax benefit of state taxes, interest and penalties.
Tax assets associated with uncertain tax positions primarily represent our estimate of the potential tax benefits in one tax jurisdiction that could result from the payment of income taxes in another jurisdiction. At December 31, 2016 and 2015, we had approximately $16.7 million and $16.5 million, respectively, in assets associated with uncertain tax positions recorded in other assets, net in our Consolidated Balance Sheets.
A reconciliation of the beginning and ending amount of gross unrecognized tax benefits included as other liabilities in our Consolidated Balance Sheets was as follows:
 
2016
 
2015
 
(Dollars in thousands)
Balance at January 1,
$
50,337

 
$
48,143

Increase based upon tax positions of current year
5,955

 
3,853

Increase based upon tax positions of a prior year
217

 
988

Increase (decrease) due to acquisitions
1,810

 
(1,327
)
Decrease based upon settlements with taxing authorities
(1,159
)
 

Decrease based upon a lapse in the statute of limitations
(439
)
 
(1,320
)
Balance at December 31,
$
56,721

 
$
50,337


The total amount of unrecognized tax benefits that would impact the effective tax rate, if recognized, at December 31, 2016 and 2015 were $21.3 million and $15.8 million, respectively.
Silgan and its subsidiaries file U.S. Federal income tax returns, as well as income tax returns in various states and foreign jurisdictions. The Internal Revenue Service, or IRS, completed its review of the 2015 tax year, and we have been accepted into the Compliance Assurance Program for the 2016 and 2017 tax years which provides for the review by the IRS of tax matters relating to our tax return prior to filing. We are subject to examination by state and local tax authorities generally for the period mandated by statute, with the exception of states where waivers of the statute of limitations have been executed. These states and the earliest open period include Wisconsin (2006), Nebraska (2006) and California (2011). Our foreign subsidiaries are generally not subject to examination by tax authorities for periods before 2008, and we have contractual indemnities with third parties with respect to open periods that predate our ownership of certain foreign subsidiaries. Subsequent periods may be examined by the relevant tax authorities. We do not expect a material change to our unrecognized tax benefits within the next twelve months.
We had undistributed earnings from foreign subsidiaries of $54.4 million at December 31, 2016. If the earnings of foreign subsidiaries were not indefinitely reinvested, a deferred tax liability of $19.0 million would be required, excluding the potential use of foreign tax credits in the United States.