XML 31 R21.htm IDEA: XBRL DOCUMENT

Income Taxes	6 Months Ended
Jun. 30, 2021
Income Tax Disclosure [Abstract]
Income Taxes	13. Income Taxes Upon emergence from the Chapter 11 Cases, we recognized Cancellation of Debt Income (or CODI). The Internal Revenue Code provides that a debtor in a Chapter 11 bankruptcy case may exclude CODI from taxable income but must reduce certain tax attributes. The estimated amount of CODI is $1,266.0 million, which is expected to be fully offset by a decrease in net operating losses and tax basis in assets. The actual reduction in tax attributes does not occur until the end of the calendar year and is expected to be fully offset by a corresponding decrease in valuation allowance. As a result of the emergence from bankruptcy, the Company experienced an ownership change under Section 382 of the Internal Revenue Code, which is expected to result in future annual limitations on the usage of any remaining U.S. outstanding tax attributes. On September 3, 2019, the Swiss federal government, along with the Canton of Zug, enacted tax legislation, which we refer to as Swiss Tax Reform, effective January 1, 2020. At the time Swiss Tax Reform was enacted, uncertainty with regard to the tax basis of depreciable property led us to record a $187.0 million reserve for uncertain tax positions. Further clarification has been provided by the Swiss tax authorities such that we reversed the aforementioned reserve for uncertain tax positions during the period from April 1 through April 23, 2021. The reversal was offset by a corresponding increase in valuation allowance.

Income Taxes

6 Months Ended

Jun. 30, 2021

13. Income Taxes

Upon emergence from the Chapter 11 Cases, we recognized Cancellation of Debt Income (or CODI). The Internal Revenue Code provides that a debtor in a Chapter 11 bankruptcy case may exclude CODI from taxable income but must reduce certain tax attributes. The estimated amount of CODI is $1,266.0 million, which is expected to be fully offset by a decrease in net operating losses and tax basis in assets. The actual reduction in tax attributes does not occur until the end of the calendar year and is expected to be fully offset by a corresponding decrease in valuation allowance.

As a result of the emergence from bankruptcy, the Company experienced an ownership change under Section 382 of the Internal Revenue Code, which is expected to result in future annual limitations on the usage of any remaining U.S. outstanding tax attributes.

On September 3, 2019, the Swiss federal government, along with the Canton of Zug, enacted tax legislation, which we refer to as Swiss Tax Reform, effective January 1, 2020. At the time Swiss Tax Reform was enacted, uncertainty with regard to the tax basis of depreciable property led us to record a $187.0 million reserve for uncertain tax positions. Further clarification has been provided by the Swiss tax authorities such that we reversed the aforementioned reserve for uncertain tax positions during the period from April 1 through April 23, 2021. The reversal was offset by a corresponding increase in valuation allowance.

- Definition

The entire disclosure for income taxes. Disclosures may include net deferred tax liability or asset recognized in an enterprise's statement of financial position, net change during the year in the total valuation allowance, approximate tax effect of each type of temporary difference and carryforward that gives rise to a significant portion of deferred tax liabilities and deferred tax assets, utilization of a tax carryback, and tax uncertainties information.

+ References + Details