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Income Taxes
12 Months Ended
Dec. 31, 2023
Income Tax Disclosure [Abstract]  
Income Taxes 9. Income Taxes

The provisions for taxes on income and the related income before taxes for the years ended December 31, 2023, 2022 and 2021, were as follows:

 

(In thousands)

 

2023

 

 

2022

 

 

2021

 

Taxes on Income

 

 

 

 

 

 

 

 

 

Federal

 

 

 

 

 

 

 

 

 

Current (1)

 

$

(22,215

)

 

$

39,328

 

 

$

35,057

 

Deferred (1)

 

 

20,268

 

 

 

(20,636

)

 

 

(25,653

)

State

 

 

 

 

 

 

 

 

 

Current (1)

 

 

(1,188

)

 

 

9,875

 

 

 

9,320

 

Deferred (1)

 

 

444

 

 

 

(6,943

)

 

 

(6,556

)

Foreign

 

 

 

 

 

 

 

 

 

Current

 

 

13,287

 

 

 

19,799

 

 

 

23,870

 

Deferred

 

 

(2,409

)

 

 

127

 

 

 

(1,396

)

Total

 

$

8,187

 

 

$

41,550

 

 

$

34,642

 

Income before Taxes

 

 

 

 

 

 

 

 

 

Domestic

 

$

11,693

 

 

$

103,831

 

 

$

77,696

 

Foreign

 

 

36,698

 

 

 

84,872

 

 

 

94,841

 

Total

 

$

48,391

 

 

$

188,703

 

 

$

172,537

 

 

(1)
In 2023 for the 2022 U.S. tax returns (federal and state), a U.S. tax accounting method change was made for the 2018-2021 tax years and additional assets that qualified for bonus depreciation under IRC 168(k) were identified. Said items increased the income tax receivable with an offset to current tax expense and created deferred tax liabilities with an offset to deferred tax expense. These amounts were booked in 2023 as a provision-to-return adjustment.

The variations between the effective and statutory U.S. federal income tax rates are summarized as follows:

 

 

 

2023 (1)

 

 

2022

 

 

2021

 

(In thousands)

 

Amount

 

 

%

 

 

Amount

 

 

%

 

 

Amount

 

 

%

 

Federal income tax provision at statutory tax rate

 

$

10,162

 

 

 

21.0

 

 

$

39,628

 

 

 

21.0

 

 

$

36,233

 

 

 

21.0

 

State income tax provision, less applicable
  federal tax benefit

 

 

(588

)

 

 

(1.2

)

 

 

2,316

 

 

 

1.2

 

 

 

2,184

 

 

 

1.3

 

Foreign income taxed at different rates

 

 

1,153

 

 

 

2.4

 

 

 

2,417

 

 

 

1.3

 

 

 

2,356

 

 

 

1.4

 

U.S. taxation of foreign earnings (2)

 

 

1,079

 

 

 

2.2

 

 

 

1,616

 

 

 

0.9

 

 

 

(134

)

 

 

(0.1

)

Unrecognized tax benefits (3)

 

 

4,090

 

 

 

8.5

 

 

 

3,324

 

 

 

1.8

 

 

 

1,775

 

 

 

1.0

 

Prior years return to provision true-up (4)

 

 

(2,424

)

 

 

(5.0

)

 

 

(1,915

)

 

 

(1.0

)

 

 

(3,314

)

 

 

(1.9

)

Stock based compensation, excess tax benefits

 

 

(1,262

)

 

 

(2.6

)

 

 

(580

)

 

 

(0.3

)

 

 

(1,287

)

 

 

(0.7

)

U.S. tax credits (5)

 

 

(4,582

)

 

 

(9.5

)

 

 

(4,508

)

 

 

(2.4

)

 

 

(2,692

)

 

 

(1.6

)

Non-deductible expenses and other items, net

 

 

559

 

 

 

1.1

 

 

 

(748

)

 

 

(0.5

)

 

 

(479

)

 

 

(0.3

)

Total income tax provision

 

$

8,187

 

 

 

16.9

 

 

$

41,550

 

 

 

22.0

 

 

$

34,642

 

 

 

20.1

 

 

(1)
In general, all permanent differences, whether positive or negative, have a more pronounced effect on the effective tax rate the lower the pre-tax income even if year-over-year the permanent differences did not change significantly.
(2)
Includes cost of global intangible low-taxed income (GILTI) in 2023, 2022 and 2021 plus other taxes paid or withheld on cash repatriated from foreign countries in 2023 and 2021. For 2023, see footnote below for the impact of repatriation withholding taxes. For 2023 and 2022, includes Subpart F activity. For 2021, includes the benefit of separate limitation loss foreign tax credit attributes, related to prior years, that were utilized in 2021.
(3)
For 2023, includes certain tax credits, transfer pricing, and the potential settlement of a foreign jurisdiction audit discussed below.
(4)
For 2023 and 2022, amount resulted from a higher federal research credit and lower GILTI. For 2021, amount resulted from a higher federal research credit, higher foreign-derived intangible income (FDII), and lower GILTI.
(5)
For 2023 and 2022, the increase was partially due to certain pilot model design and engineering costs.

At December 31, 2023 and 2022, the tax effects of significant temporary differences representing deferred tax assets and liabilities were as follows:

 

(In thousands)

 

2023

 

 

2022

 

Deferred Tax Assets:

 

 

 

 

 

 

Pensions

 

$

446

 

 

$

144

 

Deferred revenue

 

 

2,640

 

 

 

3,483

 

Other accruals and reserves

 

 

14,638

 

 

 

13,949

 

Legal and environmental accruals

 

 

7,292

 

 

 

10,283

 

Deferred compensation

 

 

12,199

 

 

 

13,845

 

Bad debt and rebate reserves

 

 

4,916

 

 

 

3,729

 

Non-U.S. subsidiaries net operating loss carryforwards

 

 

6,512

 

 

 

3,634

 

Amortization of intangibles

 

 

37,123

 

 

 

28,311

 

Inventories

 

 

8,959

 

 

 

10,577

 

Tax credit carryforwards

 

 

13,682

 

 

 

8,183

 

 

 

$

108,407

 

 

$

96,138

 

Deferred Tax Liabilities:

 

 

 

 

 

 

Depreciation

 

$

(82,907

)

 

$

(52,130

)

Unrealized foreign exchange loss

 

 

(2,784

)

 

 

(3,603

)

Other

 

 

(2,991

)

 

 

(3,064

)

 

 

$

(88,682

)

 

$

(58,797

)

Valuation Allowance

 

$

(853

)

 

$

(836

)

Net Deferred Tax Assets

 

$

18,872

 

 

$

36,505

 

Reconciliation to Consolidated Balance Sheet:

 

 

 

 

 

 

Non-current deferred tax assets (in other non-current assets)

 

 

29,245

 

 

 

46,684

 

Non-current deferred tax liabilities

 

 

(10,373

)

 

 

(10,179

)

Net Deferred Tax Assets

 

$

18,872

 

 

$

36,505

 

 

Earnings generated by a foreign subsidiary are presumed to ultimately be transferred to the parent company. Therefore, the establishment of deferred taxes may be required with respect to the excess of the investment value for financial reporting over the tax basis of investments in those foreign subsidiaries (also referred to as book-over-tax outside basis differences). A company may overcome this presumption and forgo recording a deferred tax liability in its financial statements if it can assert that management has the intent and ability to indefinitely reinvest the earnings of its foreign subsidiaries. Pursuant to the 2017 U.S. Tax Cuts and Jobs Act (Tax Act), the Company’s foreign earnings have been subject to U.S. federal taxes. The Company now has the ability to repatriate to the U.S. parent the cash associated with these foreign earnings with little additional U.S. federal taxes. This cash may, however, be subject to foreign income and/or local country taxes if repatriated to the United States. In addition, repatriation of some foreign cash balances may be further restricted by local laws. As such, the Company intends to limit its distributions to earnings previously taxed in the U.S. or earnings that would qualify for the 100 percent dividends received deduction provided for in the Tax Act as long as such distributions would not result in any significant foreign taxes.

In 2023, the Company repatriated $54,944,000 between July and December from its Netherlands, Singapore, and Canada subsidiaries. The Company incurred an incremental tax expense of $397,000 as a result of this repatriation. The effect of the adjustment on the 2023 effective tax rate was an increase of approximately 0.8 percent. In 2022, the Company did not repatriate any cash to the U.S. parent company.

The Company evaluated its indefinite reinvestment assertion with regards to certain accumulated foreign earnings as of December 31, 2023. The Company does not consider the undistributed earnings of its Canadian subsidiary to be indefinitely reinvested in foreign operations to the extent of the subsidiary’s paid-up capital (PUC) as determined under Canadian tax law which is used to determine tax-free distributions for Canadian tax purposes. The Company also does not consider the undistributed earnings of one of its Dutch subsidiaries, and one of its Singapore subsidiaries to be indefinitely reinvested in foreign operations. A distribution from any of these subsidiaries should not result in any significant foreign taxes to the extent of the distribution limitations discussed above and therefore, the Company has not recognized a deferred tax liability for these undistributed earnings as of December 31, 2023. The Company considers the undistributed earnings of its remaining foreign subsidiaries to be indefinitely reinvested in foreign operations. At this time, the determination of deferred tax liabilities on this amount is not practicable.

The Company had non-U.S. tax loss carryforwards of $20,113,000 (pretax) as of December 31, 2023, and $10,754,000 as of December 31, 2022, that are available for use by the Company between 2024 and 2033. The Company had tax credit carryforwards of

$13,682,000 as of December 31, 2023, and $8,183,000 as of December 31, 2022, that are available for use by the Company between 2024 and 2043. The Company had non-U.S. capital loss carryforwards of $608,000 as of December 31, 2023, and $595,000 as of December 31, 2022. The Company’s capital loss carryforwards do not expire.

As of December 31, 2023 and 2022, the Company had valuation allowances of $853,000 and $836,000, respectively, which were attributable to deferred tax assets in Canada, India, the Philippines and Singapore. The realization of deferred tax assets is dependent on the generation of sufficient taxable income in the appropriate tax jurisdictions. The Company believes that it is more likely than not that the related deferred tax assets will not be realized.

As of December 31, 2023, 2022 and 2021, unrecognized tax benefits totaled $14,590,000, $10,682,000 and $7,292,000, respectively. The amount of unrecognized tax benefits that, if recognized, would favorably affect the Company’s effective income tax rate in any future periods, net of the federal benefit on state issues, was approximately $14,056,000, $10,172,000 and $6,973,000 at December 31, 2023, 2022 and 2021, respectively. The Company does not believe that the amount of unrecognized tax benefits related to its current uncertain tax positions will change significantly over the next 12 months.

The Company recognizes accrued interest and penalties related to unrecognized tax benefits as income tax expense. In 2023, the Company recognized net interest and penalty expense of $435,000 compared to $202,000 of net interest and penalty expense in 2022 and $260,000 of net interest and penalty expense in 2021. At December 31, 2023 the liability for interest and penalties was $978,000 compared to $543,000 at December 31, 2022.

The Company files income tax returns in the U.S. federal jurisdiction and various states and foreign jurisdictions. The Company is not subject to U.S. federal income tax examinations by tax authorities for years before 2016. Some foreign jurisdictions and various U.S. states jurisdictions may be subject to examination back to 2016.

During 2021, the Internal Revenue Service started its audit of the 2016-2019 tax years and expanded the years under audit to 2016-2020 in 2022. As of December 31, 2023, this audit was still open, and the Company had not been notified of any significant proposed adjustments.

Below are reconciliations of the January 1 and December 31 balances of unrecognized tax benefits for 2023, 2022 and 2021:

 

(In thousands)

 

2023

 

 

2022

 

 

2021

 

Unrecognized tax benefits, opening balance

 

$

10,682

 

 

$

7,292

 

 

$

4,735

 

Gross increases – tax positions in prior period

 

 

1,891

 

 

 

2,188

 

 

 

938

 

Gross increases – current period tax positions

 

 

2,139

 

 

 

1,617

 

 

 

1,662

 

Settlements/State voluntary disclosure

 

 

(343

)

 

 

(454

)

 

 

 

Foreign currency translation

 

 

241

 

 

 

74

 

 

 

(14

)

Lapse of statute of limitations

 

 

(20

)

 

 

(35

)

 

 

(29

)

Unrecognized tax benefits, ending balance

 

$

14,590

 

 

$

10,682

 

 

$

7,292