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Income Taxes
12 Months Ended
Dec. 31, 2014
Income Taxes [Abstract]  
Income Taxes
Note 5 – Income Taxes

Income (loss) from continuing operations before taxes and noncontrolling interests consists of the following components:

 
 
Years ended December 31,
 
 
 
2014
  
2013
  
2012
 
 
 
  
  
 
Domestic
 
$
(50,106
)
 
$
(26,065
)
 
$
(15,995
)
Foreign
  
217,249
   
202,470
   
186,032
 
 
 
$
167,143
  
$
176,405
  
$
170,037
 

Significant components of income taxes are as follows:

 
 
Years ended December 31,
 
 
 
2014
  
2013
  
2012
 
 
 
  
  
 
Current:
 
  
  
 
Federal
 
$
(27,031
)
 
$
(603
)
 
$
8,409
 
State and local
  
386
   
280
   
574
 
Foreign
  
60,282
   
51,225
   
44,351
 
   
33,637
   
50,902
   
53,334
 
Deferred:
            
Federal
  
7,999
   
2,215
   
(8,557
)
State and local
  
204
   
92
   
(240
)
Foreign
  
7,460
   
(573
)
  
1,969
 
   
15,663
   
1,734
   
(6,828
)
Total income tax expense
 
$
49,300
  
$
52,636
  
$
46,506
 
 
Note 5 – Income Taxes (continued)

Deferred income taxes reflect the net tax effects of temporary differences between the carrying amounts of assets and liabilities for financial reporting purposes and the amounts for income tax purposes. Significant components of the Company's deferred tax assets and liabilities are as follows:

 
 
December 31,
 
 
 
2014
  
2013
 
     
Deferred tax assets:
    
Pension and other retiree obligations
 
$
43,393
  
$
34,343
 
Inventories
  
8,013
   
8,759
 
Net operating loss carryforwards
  
198,677
   
182,691
 
Tax credit carryforwards
  
25,046
   
20,780
 
Other accruals and reserves
  
32,376
   
31,469
 
Total gross deferred tax assets
  
307,505
   
278,042
 
Less valuation allowance
  
(186,614
)
  
(183,289
)
   
120,891
   
94,753
 
Deferred tax liabilities:
        
Tax over book depreciation
  
(10,257
)
  
(10,652
)
Intangible assets other than goodwill
  
(20,507
)
  
(1,539
)
Earnings not permanently reinvested
  
(25,334
)
  
(1,652
)
Convertible debentures
  
(175,935
)
  
(162,371
)
Other - net
  
(3,590
)
  
(2,741
)
Total gross deferred tax liabilities
  
(235,623
)
  
(178,955
)
         
Net deferred tax assets (liabilities)
 
$
(114,732
)
 
$
(84,202
)


The Company makes significant judgments regarding the realizability of its deferred tax assets (principally net operating losses). The carrying value of deferred tax assets is based on the Company's assessment that it is more likely than not that the Company will realize these assets after consideration of all available positive and negative evidence.

A reconciliation of income tax expense at the U.S. federal statutory income tax rate to actual income tax provision is as follows:

 
 
Years ended December 31,
 
 
 
2014
  
2013
  
2012
 
       
Tax at statutory rate
 
$
58,500
  
$
61,742
  
$
59,513
 
State income taxes, net of U.S. federal tax benefit
  
384
   
242
   
217
 
Effect of foreign operations
  
(27,372
)
  
(18,696
)
  
(19,083
)
Tax on earnings not permanently reinvested
  
25,728
   
-
   
-
 
Unrecognized tax benefits
  
(21,603
)
  
2,862
   
6,626
 
Change in valuation allowance on non-U.S. deferred tax assets
  
-
   
(285
)
  
(4,036
)
Foreign income taxable in the U.S.
  
13,499
   
11,961
   
7,476
 
U.S. foreign tax credits
  
-
   
-
   
(4,257
)
Effect of statutory rate changes on deferred tax assets
  
226
   
(2,867
)
  
-
 
Other
  
(62
)
  
(2,323
)
  
50
 
Total income tax expense
 
$
49,300
  
$
52,636
  
$
46,506
 

Note 5 – Income Taxes (continued)

Income tax expense for the years ended December 31, 2014, 2013, and 2012 include certain discrete tax items for changes in uncertain tax positions, valuation allowances, tax rates, and other related items. These items total $1,228 (tax benefit), $4,197 (tax benefit), and $4,036 (tax benefit) in 2014, 2013, and 2012, respectively.

For the year ended December 31, 2014, the discrete items include a $1,228 benefit recorded in the fourth fiscal quarter due to the enactment of The Tax Increase Prevention Act of 2014.  The discrete items also include benefits upon the completion of certain tax examinations and lapses in the statute of limitations, offset by additional tax expenses for expected repatriation of cash and profits of non-U.S. subsidiaries to the United States, primarily to repay amounts borrowed on the revolving credit facility to provide future flexibility given the legal entity and the financial structure utilized for the Capella acquisition. The latter two items netted to an immaterial amount.

For the year ended December 31, 2013, the discrete items include a $2,867 benefit recorded in the third fiscal quarter due to a new tax law enacted in Israel in July 2013 which effectively increases the corporate income tax rate on certain types of income earned after January 1, 2014, and, therefore, increases the deferred tax assets, and a $1,330 benefit recorded in the first fiscal quarter due to the retroactive enactment of the American Taxpayer Relief Act of 2012, signed into law on January 2, 2013.

For the year ended December 31, 2012, the discrete item is the reduction of a valuation allowance on a deferred tax asset in Israel due to a merger of several of the Company's wholly-owned subsidiaries in Israel in the fourth fiscal quarter which will allow for the realization of these tax benefits that likely otherwise would have been forgone.

At December 31, 2014, the Company had the following significant net operating loss carryforwards for tax purposes:

 
   
Expires
 
     
Austria
 
$
14,515
  
No expiration
 
Belgium
  
173,541
  
No expiration
 
Brazil
  
14,876
  
No expiration
 
Germany
  
42,968
  
No expiration
 
Israel
  
62,528
  
No expiration
 
Netherlands
  
23,411
   
2015 - 2023
 
United States
  
78,784
   
2033 - 2034
 
         
California
  
53,979
   
2016 - 2034
 
Pennsylvania
  
736,159
   
2018 - 2034
 


Approximately $64,232 of the carryforwards in Belgium resulted from the Company's acquisition of BCcomponents in 2002.  Valuation allowances of $21,833 and $24,788, as of December 31, 2014 and 2013, respectively, have been recorded through goodwill for these acquired net operating losses. Prior to the adoption of updated guidance in ASC Topic 805 on January 1, 2009, if tax benefits were recognized through the utilization of these acquired net operating losses, the benefits of such loss utilization were recorded as a reduction to goodwill. After the adoption of the updated guidance on January 1, 2009, the benefits of such losses are recorded as a reduction of tax expense.

At December 31, 2014, the Company had the following significant tax credit carryforwards available:

 
 
  
Expires
 
     
U.S. Foreign Tax Credit
 
$
11,093
   
2020 - 2022
 
California Research Credit
  
10,926
  
No expiration
 
 
Note 5 – Income Taxes (continued)

At December 31, 2014, no provision has been made for U.S. federal and state income taxes on approximately $2,686,284 of foreign earnings.  Substantially all earnings generated by non-U.S. subsidiaries prior to 2014, and cash generated in 2014 which is not funding the dividend program or the Capella acquisition (as discussed below), are deemed to be reinvested outside of the United States indefinitely.  Upon distribution of those earnings in the form of dividends or otherwise, the Company would be subject to U.S. income taxes (subject to an adjustment for foreign tax credits), state income taxes, incremental foreign income taxes, and withholding taxes payable to various foreign countries.  Determination of the amount of unrecognized deferred U.S. income tax liability is not practicable because of the complexities associated with its hypothetical calculation.

In 2008, the Company recorded additional tax expense for an expected repatriation of $112,500 because such earnings were not deemed to be indefinitely reinvested outside of the United States.  During 2012 and 2014, the Company repatriated $72,100 and $4,588 of cash, respectively, which completed the repatriation program initiated in 2008.  This repatriated cash was used to reduce the amount outstanding under the Company's revolving credit facility.

During 2014, the Company borrowed $53,000 on its revolving credit facility to achieve future flexibility given the legal entity and the financial structure utilized for the Capella acquisition (see Note 2).  Subsequent to the acquisition of the noncontrolling interest in Capella on December 31, 2014, the Company expects to repatriate cash from the current earnings of non-U.S. subsidiaries to the United States primarily to repay those borrowings on the revolving credit facility, and also to realign the acquired entity structure to have Capella's U.S. subsidiary directly owned by Vishay Intertechnology, Inc.   The tax provision for the year ended December 31, 2014 includes all U.S. federal and state income taxes, incremental foreign income taxes, and withholding taxes payable related to that anticipated repatriation transaction.

The Company expects to fund the quarterly dividend program initiated in February 2014, by, at least in part, repatriating current year income of certain non-U.S. subsidiaries and providing appropriate U.S. federal and state income taxes, incremental foreign income taxes, and withholding taxes payable on that current period non-U.S. income.

Net income taxes paid were $62,051, $44,757, and $46,611 for the years ended December 31, 2014, 2013, and 2012, respectively.

See Note 19 for a discussion of the tax-related uncertainties for the pre-spin-off period of Vishay Precision Group, Inc. ("VPG"), which was spun off on July 6, 2010.
 
Note 5 – Income Taxes (continued)

The following table summarizes changes in the liabilities associated with unrecognized tax benefits:

 
 
Years ended December 31,
 
 
 
2014
  
2013
  
2012
 
 
      
Balance at beginning of year
 
$
45,877
  
$
51,771
  
$
48,152
 
Addition based on tax positions related to the current year
  
1,641
   
-
   
665
 
Addition based on tax positions related to prior years
  
6,484
   
4,015
   
3,498
 
Currency translation adjustments
  
(1,387
)
  
310
   
(215
)
Reduction based on tax positions related to prior years
  
-
   
(2,054
)
  
-
 
Reduction for settlements
  
(3,556
)
  
(7,316
)
  
(329
)
Reduction for lapses of statute of limitation
  
(22,476
)
  
(849
)
  
-
 
Balance at end of year
 
$
26,583
  
$
45,877
  
$
51,771
 

All of the unrecognized tax benefits of $26,583 and $45,877, as of December 31, 2014 and 2013, respectively, would reduce the effective tax rate if recognized.

The Company recognizes interest and penalties related to unrecognized tax benefits in income tax expense. At December 31, 2014 and 2013, the Company had accrued interest and penalties related to the unrecognized tax benefits of $3,104 and $7,766, respectively. During the years ended December 31, 2014, 2013, and 2012, the Company recognized $1,839, $2,218, and $2,833, respectively, in interest and penalties.

The Company and its subsidiaries file U.S. federal income tax returns, as well as tax returns in multiple state and foreign jurisdictions.  During the years ended December 31, 2014 and 2013, certain tax examinations were completed and certain statutes of limitations lapsed.  The tax provision for those years includes adjustments related to the resolution of these matters, as reflected in the table above.  In 2014, the U.S. Internal Revenue Service concluded its examination of Vishay's U.S. federal tax returns through the 2011 tax year.  The tax returns of other non-U.S. subsidiaries which are currently under examination include France (2012 and 2013), Germany (2009 through 2012), India (2004 through 2012), Israel (2009 through 2012), and the Republic of China (Taiwan) (2012).  The Company and its subsidiaries also file income tax returns in other taxing jurisdictions in the U.S. and around the world, many of which are still open to examinations.

The timing of the resolution of income tax examinations is highly uncertain, as are the amounts and timing of tax payments that result from such examinations.  These events could cause large fluctuations in the balance sheet classification of current and non-current unrecognized tax benefits.  The Company believes that in the next 12 months it is reasonably possible that certain income tax examinations will conclude or the statutes of limitation on certain income tax periods open to examination will expire, or both.  Given the uncertainties described above, the Company can only determine an estimate of potential decreases in unrecognized tax benefits ranging from $2,400 to $2,700.