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Income Taxes
 6 Months Ended
Jun. 30, 2022
Income Tax Disclosure [Abstract]  
Income Taxes
Tax Rate
A reconciliation between the U.S. federal statutory tax rate and our effective tax rate is summarized as follows:
For the Three Months Ended June 30,For the Six Months Ended June 30,
 2022202120222021
Statutory rate21.0 %21.0 %21.0 %21.0 %
State taxes0.6 1.3 0.4 1.1 
Taxes on foreign earnings(3.8)(7.7)(5.3)(9.1)
Tax credits(1.4)(2.9)(1.6)(3.3)
Purchased intangible assets0.1 (0.8)0.2 (0.1)
GILTI0.2 1.5 0.2 1.3 
Sale of Samsung Bioepis(3.7)— (2.9)— 
Litigation agreement in principle8.5 — 6.7 — 
Neurimmune tax impacts— (83.1)5.2 (46.3)
International reorganization(4.0)— (3.1)— 
Other(0.4)0.4 0.4 0.6 
Effective tax rate17.1 %(70.3)%21.2 %(34.8)%
Changes in Tax Rate
For the three and six months ended June 30, 2022, compared to the same periods in 2021, the increases in our effective tax rate were primarily due to the overall current year unfavorable tax rate impact on the sale of our equity interest in Samsung Bioepis in April 2022, the litigation agreement in principle and the tax benefit recorded in the second quarter of 2021 related to the Neurimmune SubOne AG (Neurimmune) deferred tax asset matter, as discussed below. These effective tax rate increases were partially offset by the non-cash tax effects of changes in the value of our equity instruments and the current year tax benefits recorded in the second quarter of 2022 related to an international reorganization to align with global tax developments.
For the six months ended June 30, 2022, compared with the same period in 2021, our effective tax rate also increased as a result of the Neurimmune valuation allowance recorded in the first quarter of 2022.
During the second quarter of 2021 we recorded a net deferred tax asset in Switzerland of approximately $490.0 million on Neurimmune's tax basis in ADUHELM, the realization of which is dependent on future sales of ADUHELM. During the fourth quarter of 2021, due to reduced future expected revenue associated with ADUHELM, we recorded a valuation allowance of approximately $390.0 million.
During the first quarter of 2022, upon issuance of the final NCD related to ADUHELM, we recorded an additional valuation allowance of approximately $85.0 million to reduce the net value of this deferred tax asset to zero. These adjustments to our deferred tax assets and their valuation allowances are each recorded with an equal and offsetting amount assigned to net income (loss) attributable to noncontrolling interests, net of tax in our condensed consolidated statements of income, resulting in a zero net impact to net income attributable to Biogen Inc.
For additional information on the litigation agreement in principle, please read Note 19, Litigation, to these condensed consolidated financial statements.
For additional information on our collaboration arrangement with Neurimmune, please read Note 18, Investments in Variable Interest Entities, to these condensed consolidated financial statements.
Accounting for Uncertainty in Income Taxes
We and our subsidiaries are routinely examined by various taxing authorities. We file income tax returns in various U.S. states and in U.S. federal and other foreign jurisdictions. With few exceptions, we are no longer subject to U.S. federal tax examination for years before 2017 or state, local or non-U.S. income tax examinations for years before 2012.
The U.S. Internal Revenue Service and other national tax authorities routinely examine our intercompany transfer pricing with respect to intellectual property related transactions and it is possible that they may disagree with one or more positions we have taken with respect to such valuations.
It is reasonably possible that we will adjust the value of our uncertain tax positions related to certain transfer pricing, collaboration matters and other issues as we receive additional information from various taxing authorities, including reaching settlements with such authorities.
We estimate that it is reasonably possible that our gross unrecognized tax benefits, exclusive of interest, could
decrease by up to approximately $500.0 million, including approximately $455.0 million related to the unrecognized
tax benefits related to Neurimmune's tax basis in ADUHELM, in the next 12 months as a result of various audit
closures, settlements and expiration of the statute of limitations. Any changes to our gross unrecognized tax benefits related to Neurimmune's tax basis in ADUHELM would result in a zero net impact to net income attributable to Biogen, Inc., as w