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Income Taxes
12 Months Ended
Sep. 30, 2020
Income Tax Disclosure [Abstract]  
Income Taxes Income Taxes
Selected income tax data (in millions):
 
 
2020
 
2019
 
2018
Components of income before income taxes:
 
 
 
 
 
 
United States
 
$
556.2

 
$
280.8

 
$
721.6

Non-United States
 
579.9

 
620.2

 
609.2

Total
 
$
1,136.1

 
$
901.0

 
$
1,330.8


Components of the income tax provision:
 
 
 
 
 
 
Current:
 
 
 
 
 
 
United States
 
$
68.1

 
$
105.6

 
$
475.3

Non-United States
 
96.6

 
112.1

 
131.4

State and local
 
13.9

 
16.5

 
18.1

Total current
 
178.6

 
234.2

 
624.8

Deferred:
 
 
 
 
 
 
United States
 
(32.8
)
 
(27.0
)
 
118.6

Non-United States
 
(24.7
)
 
(0.1
)
 
48.0

State and local
 
(8.2
)
 
(1.9
)
 
3.9

Total deferred
 
(65.7
)
 
(29.0
)
 
170.5

Income tax provision
 
$
112.9

 
$
205.2

 
$
795.3

 
 
 
 
 
 
 
Total income taxes paid
 
$
187.9

 
$
293.3

 
$
222.9


Effective Tax Rate Reconciliation
The reconciliation between the U.S. federal statutory rate and our effective tax rate was:
 
 
2020
 
2019
 
2018
Statutory tax rate
 
21.0
 %
 
21.0
 %
 
24.5
 %
State and local income taxes
 
0.8

 
0.1

 
1.0

Non-United States taxes
 
(5.2
)
 
(4.8
)
 
(4.4
)
Repatriation of foreign earnings
 
1.3

 
2.8

 
4.2

Foreign-derived intangible income
 
(1.0
)
 
(1.6
)
 

Impact of the Tax Act
 

 

 
36.6

Sensia formation
 
(1.1
)
 

 

Change in valuation allowance(a)
 
(2.7
)
 
7.6

 
0.7

Share-based compensation
 
(1.9
)
 
(0.9
)
 
(1.3
)
Research and development tax credit
 
(1.1
)
 
(1.2
)
 
(1.3
)
Other
 
(0.2
)
 
(0.2
)
 
(0.2
)
Effective income tax rate
 
9.9
 %
 
22.8
 %
 
59.8
 %

(a) During fiscal year 2020, we reversed a portion of our valuation allowance against deferred tax assets associated with the change in fair value of the PTC Shares. This resulted in a decrease to the effective tax rate of 2.7% and a corresponding valuation allowance of $30.1 million, as described further in the table below.
We operate in certain non-U.S. tax jurisdictions under government-sponsored tax incentive programs. The program which generates the primary benefit has been extended, conditional upon meeting certain additional requirements, to 2032. The tax benefit attributable to these programs was $59.1 million ($0.51 per diluted share) in 2020, $55.1 million ($0.46 per diluted share) in 2019 and $52.3 million ($0.41 per diluted share) in 2018.

Deferred Taxes
The tax effects of temporary differences that give rise to our net deferred income tax assets (liabilities) were (in millions):
 
 
2020
 
2019
Deferred income tax assets:
 
 
 
 
Compensation and benefits
 
$
6.0

 
$
6.0

Inventory
 
10.5

 
11.1

Returns, rebates and incentives
 
34.5

 
29.8

Retirement benefits
 
306.8

 
298.5

Environmental remediation and other site-related costs
 
23.8

 
26.2

Share-based compensation
 
18.6

 
21.6

Other accruals and reserves
 
68.4

 
46.9

Investments
 
31.6

 
69.6

Net operating loss carryforwards
 
31.1

 
18.5

Tax credit carryforwards
 
17.3

 
16.5

Capital loss carryforwards
 
10.8

 
9.5

Other
 
16.8

 
10.7

Subtotal
 
576.2

 
564.9

Valuation allowance
 
(58.0
)
 
(93.8
)
Net deferred income tax assets
 
518.2

 
471.1

Deferred income tax liabilities:
 
 
 
 
Property
 
(48.0
)
 
(55.8
)
Intangible assets
 
(25.3
)
 
(24.4
)
Unremitted earnings of foreign subsidiaries
 
(28.3
)
 
(25.5
)
Other
 
(1.0
)
 
(1.3
)
Deferred income tax liabilities
 
(102.6
)
 
(107.0
)
Total net deferred income tax assets
 
$
415.6

 
$
364.1


We believe it is more likely than not that we will realize our deferred tax assets through the reduction of future taxable income, other than for the deferred tax assets reflected below.
Tax attributes and related valuation allowances at September 30, 2020 were (in millions):
Tax attributes and related valuation allowances
 
Tax Benefit Amount
 
Valuation Allowance
 
Carryforward
Period Ends
Non-United States net operating loss carryforward
 
$
19.0

 
$
5.8

 
2021
-
2030
Non-United States net operating loss carryforward
 
4.9

 
4.0

 
Indefinite
Non-United States capital loss carryforward
 
10.8

 
10.8

 
Indefinite
United States credit carryforward
 
1.1

 
1.1

 
2021
 
2030
United States net operating loss carryforward
 
0.3

 

 
2021
-
2036
State and local net operating loss carryforward
 
6.9

 
1.4

 
2021
-
2038
State tax credit carryforward
 
16.2

 
0.7

 
2021
-
2035
Subtotal
 
59.2

 
23.8

 
 
 
 
Other deferred tax assets
 
34.2

 
34.2

 
Indefinite
Total
 
$
93.4

 
$
58.0

 
 
 
 

Unrecognized Tax Benefits
A reconciliation of our gross unrecognized tax benefits, excluding interest and penalties, is as follows (in millions):
 
 
2020
 
2019
 
2018
Gross unrecognized tax benefits balance at beginning of year
 
$
19.9

 
$
20.1

 
$
31.1

Additions based on tax positions related to the current year
 

 

 

Additions based on tax positions related to prior years
 
5.6

 

 
3.0

Reductions based on tax positions related to prior years
 

 

 
(1.1
)
Reductions related to settlements with taxing authorities
 

 

 
(11.3
)
Reductions related to lapses of statute of limitations
 

 
(0.2
)
 
(1.6
)
Effect of foreign currency translation
 

 

 

Gross unrecognized tax benefits balance at end of year
 
$
25.5

 
$
19.9

 
$
20.1


The amount of gross unrecognized tax benefits that would reduce our effective tax rate if recognized was $25.5 million, $19.9 million and $20.1 million at September 30, 2020, 2019 and 2018, respectively.
Accrued interest and penalties related to unrecognized tax benefits were $4.0 million and $3.3 million at September 30, 2020 and 2019, respectively. We recognize interest and penalties related to unrecognized tax benefits in the income tax provision. Benefits (expense) recognized were ($0.7) million, ($0.8) million and $1.5 million in 2020, 2019 and 2018, respectively.
We believe it is reasonably possible that the amount of gross unrecognized tax benefits could be reduced by up to $24.6 million in the next 12 months as a result of the resolution of tax matters in various global jurisdictions and the lapses of statutes of limitations. If all of the unrecognized tax benefits were recognized, the net reduction to our income tax provision, including the recognition of interest and penalties and offsetting tax assets, could be up to $26.8 million.
We conduct business globally and are routinely audited by the various tax jurisdictions in which we operate. We are no longer subject to U.S. federal income tax examinations for years before 2016 and are no longer subject to state, local and non-U.S. income tax examinations for years before 2009.
Income tax liabilities of $296.0 million and $327.2 million related to the U.S. transition tax under the Tax Act that are payable greater than 12 months from September 30, 2020, and 2019, respectively, are recorded in other liabilities in the Consolidated Balance Sheet.