Income before income taxes, based on geographic location of the operations to which such earnings are attributable, is provided below. As the Company has elected to treat certain foreign subsidiaries as branches for U.S. income tax purposes, pretax income attributable to the United States shown below may differ from the pretax income reported in the Company’s annual U.S. federal income tax return.


	2020		2019		2018
Current:
Federal	$	40.3	$	20.8	$	46.1
State and local	7.9		4.8		9.9
Foreign	78.9		81.0		68.0
	$	127.1	$	106.6	$	124.0
Deferred:
Federal	$	(19.5)	$	39.8	$	(19.9)
State and local	(1.3)		6.5		(0.7)
Foreign	(2.4)		(55.2)		(0.8)
	$	(23.2)	$	(8.9)	$	(21.4)
United States and foreign tax provision on income	$	103.9	$	97.7	$	102.6

The following table is the reconciliation between the provision for income taxes and the amount computed by applying the U.S. federal income tax rate of 21% to income before taxes:


	2020			2019			2018
Income tax at the U.S. federal statutory rate	$	83.2		$	99.2		$	85.7
Adjustments:
State and local income taxes, net of federal tax benefit	4.8			7.4			6.8
Tax on foreign remittances and U.S. tax on foreign income	22.5			26.4			21.1
Tax expense related to undistributed earnings of foreign subsidiaries	0.1			6.0			—
Foreign losses without current tax benefits	2.5			3.2			3.7
Foreign earnings taxed at different rates including tax holidays	11.1			12.6			11.1

U.S. foreign tax credit	(13.8)			(18.3)			(21.2)
Accruals and settlements related to tax audits	3.4			11.1			(3.8)
Valuation allowance changes	(0.7)			(44.5)			—
Deferred taxes related to branch operations	—			5.3			—
U.S. Tax Reform	—			—			(10.6)
Other tax rate change	0.8			(5.0)			(2.4)
Other items, net	(10.0)			(5.7)			12.2
Provision for income taxes	$	103.9		$	97.7		$	102.6
Effective income tax rate	26.2		%	20.7		%	25.1		%

The Company released $44.5 million of foreign valuation allowances for the year ended December 31, 2019, $40.7 million of which relates to the valuation allowance that was recorded against German indefinite-lived loss carryforwards and pension deferred tax assets. Once established, the valuation allowance is released when, based on the weight of all available evidence, management concludes that related deferred tax assets are more likely than not to be realized. As a result of the execution of a tax planning strategy in the fourth quarter of 2019, management reached this conclusion and accordingly released the valuation allowance. Because the local German entity is treated as a branch under U.S. tax law, the valuation allowance release was partially offset by income tax expense of $5.3 million related to a U.S. deferred tax liability.

U.S. Tax Reform reduced the U.S. federal statutory rate from 35% to 21% beginning in 2018. U.S. Tax Reform also required companies to pay a one-time net charge related to the taxation of unremitted foreign earnings and to remeasure its U.S. deferred tax balances to the lower corporate income tax rate for the 2017 tax year. Additionally, U.S. Tax Reform created taxes on certain foreign sourced earnings known as the global intangible low-taxed income (“GILTI”) tax beginning with tax year 2018. The Company has elected to account for GILTI as a period cost in the year the tax is incurred. The accounting for the tax effects of U.S. Tax Reform was completed as of December 31, 2018 under Staff Accounting Bulletin No. 118.

For the year ended December 31, 2018, the Company recorded $8.2 million of tax benefit for changes to the provisional estimate for the remeasurement of net U.S. deferred tax balances as a result of adjustments to finalize purchase accounting for prior-year acquisitions, the remeasurement of anticipatory tax credits for foreign branches and changes to U.S. deferred tax assets included in the 2017 U.S. federal income tax return. Over the same period, the Company recorded $2.4 million of tax benefit for changes in the provisional estimate of the 2017 one-time net charge related to the taxation of unremitted foreign earnings as a result of additional federal and state regulatory guidance issued and the filing of the Company's 2017 U.S. federal income tax return.

There are no changes to the Company’s assertion about its permanent reinvestment in undistributed foreign earnings. The Company recorded $0.1 million and $6.0 million of income tax expense related to foreign withholding taxes on planned one-time distribution for the years ended December 31, 2020 and 2019, respectively. No additional deferred taxes have been recorded for any other outside basis differences as these amounts continue to be indefinitely reinvested in foreign operations. The amounts of undistributed foreign earnings were $810.3 million and $785.3 million at December 31, 2020 and December 31, 2019, respectively. It is not practicable to calculate the additional taxes that might be payable on such unremitted earnings due to the variety of circumstances and tax laws applicable at the time of distribution.


	2020		2019
Deferred tax assets:
Accrued postretirement benefits cost	$	15.4	$	0.1
Accrued pension cost	57.4		55.1
Other employee benefit accruals	11.0		10.9
Tax loss and credit carryforwards	90.2		86.0
Other, net	46.7		46.9
Valuation allowances	(36.7)		(33.7)
	$	184.0	$	165.3
Deferred tax liabilities - principally depreciation and amortization	(255.7)		(261.6)
Net deferred tax (liabilities) assets	$	(71.7)	$	(96.3)

The Company has U.S. federal and state tax credit and loss carryforwards with tax benefits totaling $6.7 million, portions of which will expire in 2021 and continue until 2040. In addition, the Company has loss carryforwards in various non-U.S. jurisdictions with tax benefits totaling $83.5 million, portions of which will expire in 2021 while others will be carried forward indefinitely. The Company has provided valuation allowances of $35.9 million against certain of these carryforwards and $0.8 million against other deferred tax assets. A majority of the non-U.S. loss carryforwards represent local country net operating losses for branches of the Company or entities treated as branches of the Company under U.S. tax law for which deferred taxes have been recorded.

As of December 31, 2020, the Company had $45.6 million of total gross unrecognized tax benefits, $39.2 million of which would favorably impact the Company’s effective income tax rate in any future period if such benefits were recognized. As of December 31, 2020, the Company believes it is reasonably possible that the amount of unrecognized tax positions could decrease by approximately $8.4 million during the next 12 months. The potential decrease would be primarily driven by settlements with tax authorities and the expiration of various applicable statutes of limitation. As of December 31, 2020, the Company had accrued $8.6 million of interest and penalties related to uncertain tax positions. The Company records interest and penalties related to uncertain tax positions as a component of income tax expense.

As of December 31, 2019, the Company had $38.9 million of total gross unrecognized tax benefits, $36.1 million of which would favorably impact the Company’s effective income tax rate in any future period if such benefits were recognized. As of December 31, 2019, the Company had accrued $5.0 million of interest and penalties related to uncertain tax positions. The Company records interest and penalties related to uncertain tax positions as a component of income tax expense.

As of December 31, 2018, the Company had $26.0 million of total gross unrecognized tax benefits, all of which would favorably impact the Company’s effective income tax rate in any future period if such benefits were recognized. As of December 31, 2018, the Company had accrued $2.5 million of interest and penalties related to uncertain tax positions. The Company records interest and penalties related to uncertain tax positions as a component of income tax expense.


	2020		2019		2018
Beginning balance, January 1	$	38.9	$	26.0	$	14.0
Tax positions related to the current year:
Additions	2.2		3.6		0.4
Tax positions related to prior years:
Additions	8.7		11.7		17.8
Reductions	(1.0)		(1.1)		(2.9)
Settlements with tax authorities	(0.3)		(1.2)		(2.2)
Lapses in statutes of limitation	(2.9)		(0.1)		(1.1)
Ending balance, December 31	$	45.6	$	38.9	$	26.0

During 2020, gross unrecognized tax benefits increased primarily for additional accruals for uncertain tax positions related to non-U.S. transfer pricing along with prior year tax matters in multiple jurisdictions related to previous acquisitions and non-deductible expenses. These increases were partially offset by releases of accrual for lapses in statutes of limitations.

During 2019, gross unrecognized tax benefits increased primarily for additional accruals for uncertain tax positions related to U.S. Tax Reform along with prior year tax matters in multiple jurisdictions related to acquisitions. These increases were partially offset by settlements with the tax authorities for prior year tax matters related to the Company’s foreign operations.

During 2018, gross unrecognized tax benefits increased primarily for prior year tax matters in multiple jurisdictions related to acquisitions. These increases were partially offset by settlements with the tax authorities for prior year tax matters related to the Company’s international operations.

As of December 31, 2020 the Company is subject to examination by the IRS for tax years 2017 to the present. The Company also is subject to tax examination in various U.S. state and local tax jurisdictions for tax years 2013 to the present, as well as various foreign tax jurisdictions, including Mexico, China, Poland, France, Germany and India for tax years as early as 1999 to the present. The Company’s unrecognized tax benefits were presented on the Consolidated Balance Sheets as a component of other non-current liabilities and as a reduction to deferred income taxes.