Income Taxes (Tables)
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12 Months Ended |
Dec. 31, 2022 |
Income Tax Disclosure [Abstract] |
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Schedule of Income before Income Tax, Domestic and Foreign |
For income tax purposes, the domestic and foreign components of (Loss) income from continuing operations before income taxes were as follows:
| | | | | | | | | | | | | | | | | | | Year Ended | (In millions of U.S. Dollars) | December 31, 2022 | | December 25, 2021 | | December 26, 2020 | Domestic | $ | (79.4) | | | $ | (66.5) | | | $ | (64.4) | | Foreign | 78.7 | | | 263.4 | | | 274.8 | | Income before income taxes | $ | (0.7) | | | $ | 196.9 | | | $ | 210.4 | |
Therefore, the Company has not provided any deferred tax impacts of GILTI in the Consolidated Financial Statements. GILTI tax costs before utilization of GILTI credits was: | | | | | | | | | | | | | | | | | | | Year Ended | | December 31, 2022 | | December 25, 2021 | | December 26, 2020 | Tax cost associated with GILTI (before credits) | $ | 7.4 | | | $ | 28.7 | | | $ | 20.0 | |
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Schedule of Components of Income Tax Expense (Benefit) |
The provisions for current and deferred taxes are summarized as follows:
| | | | | | | | | | | | | | | | | | | Year Ended | (In millions of U.S. Dollars) | December 31, 2022 | | December 25, 2021 | | December 26, 2020 | United States | $ | 3.0 | | | $ | 3.4 | | | $ | 8.3 | | International | 39.2 | | | 67.5 | | | 76.5 | | State and local | (0.1) | | | 1.9 | | | 0.1 | | Current provision for income taxes | 42.1 | | | 72.8 | | | 84.9 | | | | | | | | United States | 120.7 | | | (24.8) | | | 3.1 | | International | 76.3 | | | 2.5 | | | (2.4) | | State and local | 7.1 | | | (4.6) | | | 2.0 | | Deferred provision for income taxes | 204.1 | | | (26.9) | | | 2.7 | | | | | | | | Provision for income taxes | $ | 246.2 | | | $ | 45.9 | | | $ | 87.6 | |
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Schedule of Effective Income Tax Rate Reconciliation |
A reconciliation of the provision for income taxes and income taxes computed using the United States federal statutory rate were as follows:
| | | | | | | | | | | | | | | | | | | Year Ended | (In millions of U.S. Dollars) | December 31, 2022 | | December 25, 2021 | | December 26, 2020 | Provision for income taxes using statutory rate | $ | (0.2) | | | $ | 41.4 | | | $ | 44.2 | | Foreign rate differential | 19.8 | | | 11.9 | | | 15.1 | | Changes in valuation allowances for deferred tax assets | 191.5 | | | (33.7) | | | 14.2 | | Accrued withholding tax on unrepatriated earnings | 12.3 | | | 0.8 | | | 0.5 | | Global intangible low-taxed income and other foreign inclusions, net of credits | 14.9 | | | 1.6 | | | 10.0 | | Foreign direct taxes in excess of credits | 3.1 | | | 2.6 | | | 6.1 | | Impact of equity based compensation | 1.3 | | | 2.3 | | | 1.6 | | Foreign-derived intangible income, benefit | — | | | (6.8) | | | — | | Impact of changes in tax legislation | — | | | 4.4 | | | (7.9) | | Hedging Activity | (0.5) | | | 3.0 | | | (0.8) | | State taxes | (0.9) | | | (1.3) | | | 2.9 | | Unrecognized tax benefits | (1.7) | | | 15.7 | | | 0.4 | | Impairment of goodwill and intangible assets | 7.5 | | | 2.7 | | | — | | Other | (0.9) | | | 1.3 | | | 1.3 | | Provision for income taxes | $ | 246.2 | | | $ | 45.9 | | | $ | 87.6 | |
The effective tax rate was:
| | | | | | | | | | | | | | | | | | | Year Ended | | December 31, 2022 | | December 25, 2021 | | December 26, 2020 | Effective tax rate | 35,171.4 | % | | 23.3 | % | | 41.6 | % |
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Schedule of Deferred Tax Assets and Liabilities |
The components of deferred tax assets (liabilities) were as follows:
| | | | | | | | | | | | | As of | (In millions of U.S. Dollars) | December 31, 2022 | | December 25, 2021 | Purchased intangible assets | $ | (0.2) | | | $ | (3.3) | | Lease assets | (20.5) | | | (19.4) | | Depreciation | (10.0) | | | (3.9) | | Accrued withholding tax on unrepatriated earnings | (24.0) | | | (11.7) | | Gross deferred tax liabilities | (54.7) | | | (38.3) | | | | | | Credit and net operating loss carryforwards (net of unrecognized tax benefits) | 144.9 | | | 203.3 | | Interest expense carryforward | 38.5 | | | 27.8 | | Employee benefits accruals | 24.9 | | | 34.3 | | Deferred costs | 20.1 | | | 25.3 | | Fixed assets basis differences | 8.8 | | | 8.5 | | Capitalized intangible assets | 13.1 | | | 13.0 | | Other accruals | 41.7 | | | 42.7 | | Accounts receivable | 5.7 | | | 5.9 | | Post-retirement benefits | 1.1 | | | 2.2 | | Lease liabilities | 21.3 | | | 20.0 | | Inventory | 65.3 | | | 55.7 | | Other | 0.5 | | | (0.5) | | Gross deferred tax assets | 385.9 | | | 438.2 | | | | | | Valuation allowances | (357.6) | | | (216.1) | | Net deferred tax (liabilities) assets | $ | (26.4) | | | $ | 183.8 | |
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Summary of Operating Loss Carryforwards |
The Company’s gross tax operating loss carryforwards have expiration dates ranging between one year and no expiration in certain instances. The gross tax operating loss carryforward balance before valuation allowance was: | | | | | | | | | | | | | As of | (In millions of U.S. Dollars) | December 31, 2022 | | December 25, 2021 | Federal | $ | — | | | $ | — | | State | 9.5 | | | 8.8 | | International | 234.8 | | | 347.8 | | Gross tax operating loss carryforwards | $ | 244.3 | | | $ | 356.6 | |
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Summary of Valuation Allowance |
The Company’s changes in its valuation allowance were:
| | | | | | | | | | | | | | | | | | | | | | | | | | | | | | (In millions of U.S. Dollars) | Balance at Beginning of Period | | Charged to Costs and Expenses | | Deductions | | Balance at End of Period | Valuation allowance for deferred tax assets: | | | | | (a) | | (b) | | | Year Ended December 31, 2022 | $ | 216.1 | | | 164.9 | | | (9.0) | | | (14.4) | | | $ | 357.6 | | Year Ended December 25, 2021 | $ | 255.5 | | | 6.4 | | | (41.3) | | | (4.5) | | | $ | 216.1 | | Year Ended December 26, 2020 | $ | 285.6 | | | 39.8 | | | (41.7) | | | (28.2) | | | $ | 255.5 | |
___________________ (a) Represents write-offs, less recoveries. (b) Foreign currency translation adjustment.
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Summary of Tax Credit Carryforwards |
The Company’s estimated foreign tax credit carryforwards have expirations ranging from one to ten years. The estimated foreign tax credit carryforwards, net of uncertain tax reserves were: | | | | | | | | | | | | | As of | (In millions of U.S. Dollars) | December 31, 2022 | | December 25, 2021 | Foreign tax credit carryforwards | $ | 86.2 | | | $ | 129.6 | |
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Summary of Deferred Tax Liability Not Recognized |
Cumulative undistributed earnings, earnings deemed to not be permanently invested, and related deferred taxes were:
| | | | | | | | | | | | (In millions of U.S. Dollars) | 2022 | | 2021 | Cumulative undistributed earnings | $ | 1,770.1 | | | $ | 2,058.7 | | Earnings deemed to not be permanently invested | $ | 1,770.1 | | | $ | 213.2 | | Deferred tax liability on earnings deemed to not be permanently invested | $ | 24.0 | | | $ | 11.7 | |
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Summary of Income Tax Contingencies |
Accrual for uncertain tax positions and interest and penalties related to uncertain tax positions were:
| | | | | | | | | | | | | As of | (In millions of U.S. Dollars) | December 31, 2022 | | December 25, 2021 | Accrual for uncertain tax positions | $ | 30.5 | | | $ | 31.0 | | Interest and penalties related to uncertain tax positions | $ | 1.9 | | | $ | 3.3 | |
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Schedule of Unrecognized Tax Benefits Rollforward |
A reconciliation of the beginning and ending amount of accrual for uncertain tax positions is as follows: | | | | | | | | | | | | | As of | (In millions of U.S. Dollars) | December 31, 2022 | | December 25, 2021 | Beginning balance | $ | 31.0 | | | $ | 14.3 | | Additions based on tax positions related to the current year | 0.5 | | | 17.7 | | Additions for tax positions of prior year | — | | | 0.8 | | Reduction for tax positions of prior years | (0.1) | | | — | | Settlements | (0.2) | | | — | | Reductions for lapse in statute of limitations | (0.3) | | | (1.3) | | Impact of foreign currency rate changes versus the United States dollar | (0.4) | | | (0.5) | | Ending balance | $ | 30.5 | | | $ | 31.0 | |
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Schedule of Supplemental Cash Flow Disclosure |
Cash flow information related to income taxes paid was: | | | | | | | | | | | | | | | | | | | Year Ended | (In millions of U.S. Dollars) | December 31, 2022 | | December 25, 2021 | | December 26, 2020 | Income taxes paid | $ | 64.3 | | | $ | 84.6 | | | $ | 66.7 | |
Supplemental cash flow information related to Long-term debt and other lease financing obligations is as follows:
| | | | | | | | | | | | | | | | | | | Year Ended | (In millions of U.S. Dollars) | December 31, 2022 | | December 25, 2021 | | December 26, 2020 | Noncash financing activity - financing liability incurred following a sale-leaseback transaction | $ | 0.3 | | | $ | 0.3 | | | $ | 2.5 | |
Interest paid on total debt was: | | | | | | | | | | | | | | | | | | | Year Ended | (In millions of U.S. Dollars) | December 31, 2022 | | December 25, 2021 | | December 26, 2020 | Interest cash payments | $ | 28.5 | | | $ | 35.0 | | | $ | 36.7 | |
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