Income Taxes

12 Months Ended

Dec. 31, 2021

Income Tax Disclosure [Abstract]

Income Taxes

Income Taxes

As a global organization, we and our subsidiaries file income tax returns in the U.S. federal jurisdiction and various state and foreign jurisdictions. As of December 31, 2021, the statute of limitations for the U.S. federal tax years 2017 through 2021 remain open to examination. For U.S. state and local jurisdictions, tax years 2013 through 2021 are open to examination. We are also subject to examination in various foreign jurisdictions for tax years 2014 through 2021.

A reconciliation of the beginning and ending amount of the liability for unrecognized tax benefits is as follows:

($ in millions)	2021		2020
Balance at January 1	$	10.4	$	5.0
Increase due to current year position	16.3		4.9
(Decrease) increase due to prior year position	(1.0)		0.6
Reduction for expiration of statute of limitations/audits	(0.8)		(0.1)
Balance at December 31	$	24.9	$	10.4

In addition, we had balances in accrued liabilities for interest and penalties of $0.5 million and $0.3 million at December 31, 2021 and 2020, respectively. As of December 31, 2021, we had $24.9 million of total gross unrecognized tax benefits, which, if recognized, $16.7 million would favorably impact the effective income tax rate. It is reasonably possible that, due to the expiration of statutes and the closing of tax audits, the amount of gross unrecognized tax benefits may be reduced by approximately $0.4 million during the next twelve months, which would favorably impact our effective tax rate.

The components of income before income taxes are:

($ in millions)	2021		2020		2019
U.S. operations	$	420.0	$	227.0	$	161.2
International operations	328.9		174.3		130.6
Total income before income taxes	$	748.9	$	401.3	$	291.8

The related provision for income taxes consists of:

($ in millions)	2021		2020		2019
Current:
Federal	$	64.8	$	28.9	$	10.8
State	10.9		3.4		2.4
International	74.4		46.0		30.5
Current income tax provision	150.1		78.3		43.7
Deferred:
Federal and state	7.3		0.2		10.3
International	(50.2)		(6.0)		5.0
Deferred income tax provision	(42.9)		(5.8)		15.3
Income tax expense	$	107.2	$	72.5	$	59.0

Deferred income taxes result from temporary differences between the amount of assets and liabilities recognized for financial reporting and tax purposes.

The significant components of our deferred tax assets and liabilities at December 31 are:

($ in millions)	2021		2020
Deferred tax assets
Net operating loss carryforwards	$	14.0	$	21.4
Tax credit carryforwards	1.5		2.0
Pension and deferred compensation	31.6		35.3
Royalty acceleration	45.1		—
Other	12.2		11.0
Valuation allowance	(12.2)		(15.1)
Total deferred tax assets	92.2		54.6
Deferred tax liabilities:
Property, plant, and equipment	47.2		42.1
Tax on undistributed earnings of subsidiaries	1.8		6.5
Other	(0.4)		0.4
Total deferred tax liabilities	48.6		49.0
Net deferred tax asset (liability)	$	43.6	$	5.6

A reconciliation of the U.S. federal corporate tax rate to our effective consolidated tax rate on income before income taxes is as follows:

	2021		2020		2019
U.S. federal corporate tax rate	21.0	%	21.0	%	21.0	%
Tax on international operations other than U.S. tax rate	1.9		1.2		2.7
Adjustments to reserves for unrecognized tax benefits	0.1		1.4		0.4
U.S. tax on international earnings, net of foreign tax credits	0.3		0.4		0.4
Foreign-Derived Intangible Income Deductions (FDII)	(1.5)		(1.1)		(0.6)
State income taxes, net of federal tax effect	(0.1)		1.2		1.4
U.S. research and development credits	(0.4)		(0.7)		(1.0)
Excess tax benefits on share-based payments	(4.2)		(5.2)		(3.5)
Royalty acceleration	(2.5)		—		—
Tax on undistributed earnings of subsidiaries	(0.6)		0.1		(0.2)
Other	0.3		(0.2)		(0.4)
Effective tax rate	14.3	%	18.1	%	20.2	%

During 2021, we recorded a tax benefit of $1.4 million due to the impact of tax law changes enacted during the year, a tax benefit of $18.5 million due to the Company's prepayment of future royalties from one of its subsidiaries, and a tax benefit of $31.5 million associated with stock-based compensation.

During 2020, we recorded a tax benefit of $0.5 million due to the impact of tax law changes enacted during the year and a tax benefit of $20.8 million associated with stock-based compensation.

During 2019, we recorded a net tax benefit of $0.3 million for the estimated impact of the 2017 Tax Act and a tax benefit of $10.3 million associated with stock-based compensation.

State operating loss carryforwards of $138.6 million created a deferred tax asset of $10.6 million, while foreign operating loss carryforwards of $20.0 million created a deferred tax asset of $3.4 million. Management estimates that certain state and foreign operating loss carryforwards are unlikely to be utilized and the associated deferred tax assets have been fully reserved. In 2021, it was determined that $4.4 million of previously reserved state loss carryforwards were more likely than not to be utilized prior to expiration. State loss carryforwards expire as follows: $7.8 million in 2022 and $130.8 million thereafter. Foreign loss carryforwards will begin to expire in 2030, while $18.0 million of the total $20.0 million will not expire.

During 2019, we utilized all of our remaining U.S. federal research and development credit carryforwards. State research and development credit carryforwards of $1.0 million created a deferred tax asset of $0.8 million. As of December 31, 2021, $0.4 million of state research and development credits expire in 2025.

In response to the 2017 Tax Act, we reevaluated our position regarding permanent reinvestment of foreign subsidiary earnings and profits through 2017 (with the exception of China and Mexico) and decided that those profits were no longer permanently reinvested. As of January 1, 2018, we reasserted indefinite reinvestment related to all post-2017 unremitted earnings in all of our foreign subsidiaries. In general, it is our practice and intention to permanently reinvest the earnings of our foreign subsidiaries and repatriate earnings only when the tax impact is de minimis, and that position has not changed subsequent to the one-time transition tax under the 2017 Tax Act, except as noted above. Accordingly, no deferred taxes have been provided for withholding taxes or other taxes that would result upon repatriation of approximately $635.3 million of undistributed earnings from foreign subsidiaries to the U.S., as those earnings continue to be permanently reinvested. Further, it is impracticable for us to estimate any future tax costs for any unrecognized deferred tax liabilities associated with our indefinite reinvestment assertion, because the actual tax liability, if any, would be dependent on complex analysis and calculations considering various tax laws, exchange rates, circumstances existing when there is a repatriation, sale or liquidation, or other factors.