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Income Taxes
12 Months Ended
Dec. 31, 2013
Income Tax Disclosure [Abstract]  
Income Taxes
INCOME TAXES
Income before income taxes included the following components (in thousands):
 
Year Ended
 
2013
 
2012
 
2011
U.S.
$
32,549

 
$
26,640

 
$
14,189

Foreign
119,053

 
113,908

 
108,676

Total
$
151,602

 
$
140,548

 
$
122,865


Income tax expense consisted of the following (in thousands):
 
Year Ended
 
2013
 
2012
 
2011
Current:
 
 
 
 
 
Federal
$
(851
)
 
$
8,173

 
$
7,767

State
419

 
475

 
395

Foreign
16,513

 
13,870

 
18,559

Total current income tax expense
16,081

 
22,518

 
26,721

U.S. deferred expense (benefit)
12,645

 
4,285

 
(6,266
)
Foreign deferred benefit
(3,797
)
 
(1,175
)
 
(1,227
)
Income tax expense
$
24,929

 
$
25,628

 
$
19,228



The effective income tax rate applied to net income varied from the U.S. federal statutory rate due to the following (in thousands):
 
Year Ended
 
2013
 
2012
 
2011
Tax expense at U.S. federal statutory rates
$
53,061

 
$
49,192

 
$
43,003

Increase (decrease) resulting from:
 
 
 
 
 
State income taxes, net of federal benefit
857

 
1,126

 
723

Foreign tax benefit
(25,263
)
 
(26,181
)
 
(20,515
)
Research and experimentation benefit
(5,966
)
 
(758
)
 
(2,908
)
Foreign tax credit benefit
(2,152
)
 
(2,738
)
 
(4,465
)
Tax audit settlements and lapses of statutes of limitations
(70
)
 
(439
)
 
(509
)
Stock compensation
2,658

 
2,134

 
1,683

Non-deductible items
2,132

 
3,100

 
1,597

Other
(328
)
 
192

 
619

Income tax expense
$
24,929

 
$
25,628

 
$
19,228


Our 2013 tax expense reflected comparatively lower tax rates in foreign jurisdictions where we earn most of our profits. The tax provision also included a benefit for the reduction of unrecognized tax benefits relating to positions on prior year returns after completion of audits in various jurisdictions.
Current taxes payable were reduced for excess tax benefits recorded to common stock and related to stock compensation of $6.4 million, $3.1 million and $2.9 million, respectively, in 2013, 2012 and 2011.
Deferred Income Taxes
Net deferred tax assets (liabilities) were classified on the balance sheet as follows (in thousands):
 
December 31,
 
2013
 
2012
Deferred tax assets – current
$
15,114

 
$
12,245

Deferred tax assets – non-current
1,751

 
5,092

Deferred tax liabilities – current
(9
)
 
(93
)
Deferred tax liabilities – non-current
(8,931
)
 
(17,588
)
Net deferred tax assets (liabilities)
$
7,925

 
$
(344
)
Valuation allowance
$
2,723

 
$
2,081


The tax effects of temporary differences that gave rise to significant portions of deferred tax assets and deferred tax liabilities were as follows (in thousands):
 
December 31,
 
2013
 
2012
Deferred tax assets:
 
 
 
Accrued liabilities and reserves
$
15,804

 
$
13,239

Revenue recognition
340

 
3,707

Tax credit and loss carryforwards
8,063

 
8,497

Fixed assets and intangibles
546

 
765

Unrealized investment
765

 
2,538

Stock compensation
2,151

 
1,815

Other assets
1,501

 
665

Gross deferred tax assets
29,170

 
31,226

Valuation allowance
(2,723
)
 
(2,081
)
Net deferred tax assets
26,447

 
29,145

Deferred tax liabilities:
 
 
 
Fixed assets and intangibles
(17,965
)
 
(20,697
)
Revenue recognition
(19
)
 
(4,991
)
Other liabilities
(538
)
 
(3,801
)
Total deferred tax liabilities
(18,522
)
 
(29,489
)
Net deferred tax assets (liabilities)
$
7,925

 
$
(344
)

Deferred tax benefit of $1.1 million, $3.0 million and $3.0 million was recorded in other comprehensive income in 2013, 2012 and 2011, respectively.
As of December 31, 2013 and 2012, our valuation allowance on deferred tax assets totaled $2.7 million and $2.1 million, respectively. In assessing the realizability of deferred tax assets, we utilize a more likely than not standard. If it is determined that it is “more likely than not” that deferred tax assets will not be realized, a valuation allowance must be established against the deferred tax assets. The ultimate realization of deferred tax assets is dependent upon the generation of future taxable income during the periods in which the associated temporary differences become deductible. We consider the scheduled reversal of deferred tax liabilities, historical operating performance, projected future taxable income and tax planning strategies in making this assessment.
U.S. net operating loss carryforwards as of December 31,2013 were $0.2 million and expire in 2031. Foreign net operating loss carryforwards as of December 31, 2013 were $14.6 million and do not expire.
U.S. research and development tax credit carryforwards as of December 31, 2013 were $2.9 million and expire between 2014 and 2033. Foreign research and development tax credit carryforwards as of December 31, 2013 were $0.2 million and do not expire. Alternative minimum tax credit carryforwards as of December 31, 2013 were $0.7 million and do not expire.
As of December 31, 2013, U.S. income taxes have not been provided for approximately $331.3 million of cumulative undistributed earnings of several non-U.S. subsidiaries, as our current intention is to reinvest these earnings indefinitely outside the U.S. Foreign tax provisions have been provided for these cumulative undistributed earnings. Upon distribution of those earnings in the form of dividends or otherwise, we would be subject to both U.S. income taxes (subject to an adjustment for foreign tax credits) and withholding taxes payable to the various foreign countries. Similarly, we have not provided deferred taxes on the cumulative translation adjustment related to those non-U.S. subsidiaries.
Unrecognized Tax Benefits and Other Tax Contingencies
A rollforward of our unrecognized tax benefits, including interest and penalties, was as follows (in thousands):
 
Year Ended
 
2013
 
2012
 
2011
Unrecognized tax benefits, beginning of period
$
25,135

 
$
16,041

 
$
7,156

Increases for tax positions taken in current period
1,197

 

 
542

Increases for tax positions taken in prior periods
1,701

 
9,965

 
10,502

Decreases for tax positions taken in prior periods
(3,997
)
 
(620
)
 
(1,723
)
Decreases for lapses in statutes of limitations
(70
)
 
(251
)
 
(436
)
Unrecognized tax benefits, end of period
$
23,966

 
$
25,135

 
$
16,041


During 2013, we effectively settled matters with the Internal Revenue Service and certain foreign jurisdictions. The result of effective settlements was a reduction of $3.7 million of unrecognized tax benefits, all of which resulted in a tax benefit. This reduction was offset by accruals for positions taken on current and prior year tax returns and related mainly to uncertainty surrounding transfer pricing and permanent establishment.
Non-current unrecognized tax benefits as of December 31, 2013 and 2012 of $23.8 million and $15.7 million were classified on the balance sheet as a component of Other Liabilities.
The entire balance of unrecognized tax benefits, if recognized, would reduce our effective tax rate. We believe it is reasonably possible that our unrecognized tax benefits could decrease, in the next 12 months, between zero and $4.0 million due to lapses of statutes of limitations and as the result of settlements with taxing authorities.
We recognize interest and penalties related to unrecognized tax benefits in income tax expense. The liability for unrecognized tax benefits included accruals for interest and penalties of $3.7 million and $2.0 million as of December 31, 2013 and 2012, respectively.
Tax expense included the following relating to interest and penalties (in thousands):
 
Year Ended
 
2013
 
2012
 
2011
Benefit for lapses of statutes of limitations and settlement with taxing authorities
$
(24
)
 
$
(88
)
 
$
(124
)
Accruals for current and prior periods
1,698

 
652

 
293

Total interest and penalties
$
1,674

 
$
564

 
$
169


For our major tax jurisdictions, the following years were open for examination by the tax authorities as of December 31, 2013:
Jurisdiction
 
Open Tax Years
U.S.
 
2010 and forward
The Netherlands
 
2011 and forward
Czech Republic
 
2011 and forward