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INCOME TAXES
9 Months Ended
Sep. 30, 2018
Income Tax Disclosure [Abstract]  
INCOME TAXES

NOTE 7 – INCOME TAXES

The effective tax rates for the three months ended September 30, 2018 and 2017 were 31.7% and 41.6%, respectively.  The effective tax rates for the nine months ended September 30, 2018 and 2017 were 26.9% and 23.9%, respectively.  The decrease in the tax rate for the three months ended September 30, 2018, when compared to the three months ended September 30, 2017 is a result of the reduction in the U.S. federal tax rate from 35.0% to 21.0% in accordance with the U.S. Tax Cuts and Jobs Act of 2017 (the “U.S. Tax Act”) effective for tax years beginning after December 31, 2017, partially offset by the non-deductibility of the foreign exchange loss recorded for the impact of the change in functional currency of our operations in Argentina (see Note 1 – Basis of Presentation and Summary Of Significant Accounting Policies).  The higher rate for the nine months ended September 30, 2018, when compared to the nine months ended September 30, 2017 is a result of the impact to the annual effective rate of the accrual, in the second quarter, of the SQ customer class action settlement. The result was proportionally lower U.S. pre-tax income compared to international operations than in the current year.

In accordance with Staff Accounting Bulletin No. 118 (“SAB118”) and Accounting Standards Update No. 2018-05 “Income Taxes (Topic 740), Amendments to SEC paragraphs pursuant to SEC Staff Accounting Bulletin No. 118”, the Company recognized the provisional tax impacts related to the re-measurement of our deferred income tax assets and liabilities and the one-time, mandatory transition tax on deemed repatriation during the year ended December 31, 2017.  During the three months ended September 30, 2018, we recorded $0.4 million in measurement-period adjustments related to these items.  Such adjustments may be necessary in future periods due to, among other things, the significant complexity of the Act and anticipated additional regulatory guidance that may be issued by the U.S. Internal Revenue Service (“IRS”), changes in analysis, interpretations and assumptions the Company has made and actions the Company may take as a result of the U.S. Tax Act.

The $295.0 million SQ customer class action settlement payment, made in the third quarter, of 2018 is a current year tax deduction which we anticipate will result in the generation of a net operating loss on our U.S. federal tax return that will be carried forward to future years and is expected to be fully utilized. The current year deduction also causes a limitation of our deductible interest expense in 2018.  Based upon our current forecast, the deferred tax asset related to this excess interest expense limitation is expected to be approximately $13.8 million.  This excess amount will also be carried forward and is expected to be fully utilized.  In addition, the Company is reviewing the overall tax treatment associated with the SQ customer class action settlement payment and the applicable tax rate to apply as a result of the U.S. Tax Act.

The Company files income tax returns in the U.S., in various states and in certain foreign jurisdictions.  The Company has recorded liabilities to cover certain uncertain tax positions.  Such uncertain tax positions relate to additional taxes that the Company may be required to pay in various tax jurisdictions.  During the course of examinations by various taxing authorities, proposed adjustments may be asserted.  The Company evaluates such items on a case-by-case basis and adjusts the accrual for uncertain tax positions as deemed necessary.

During the first quarter of 2018, the IRS completed the audit of our 2014 corporate income tax return and made no changes to our reported tax.