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Income Taxes
 9 Months Ended
Sep. 30, 2015
Income Tax Disclosure [Abstract]  
Income Taxes
Income Taxes
During the three months ended September 30, 2015 and 2014, the Company recorded an income tax benefit of $4.9 million and a tax provision of $10.2 million, respectively. During the nine months ended September 30, 2015, and 2014, the Company recorded income tax provisions of $27.0 million and $35.9 million, respectively.
The Company incurred a net loss and therefore recorded an income tax benefit during the three months ended September 30, 2015. The net loss was due to a one-time charge resulting from a settlement with the CFPB. The $10.0 million civil monetary penalty component of the CFPB settlement is not deductible for income tax purposes. Refer to Note 13, “Commitments and Contingencies,” for further discussion of the CFPB settlement.
The effective tax rates for the respective periods are shown below:
 
Three Months Ended 
 September 30,
 
Nine Months Ended 
 September 30,
 
2015
 
2014
 
2015
 
2014
Federal (benefit) provision
(35.0
)%
 
35.0
 %
 
35.0
 %
 
35.0
 %
State (benefit) provision
(4.4
)%
 
3.8
 %
 
4.4
 %
 
3.8
 %
International benefit(1)
(23.4
)%
 
(8.7
)%
 
(8.8
)%
 
(5.0
)%
Permanent items(2)
1.7
 %
 
5.7
 %
 
1.0
 %
 
4.1
 %
Tax effect of CFPB / regulatory charges
27.6
 %
 
0.0
 %
 
5.4
 %
 
0.0
 %
Other(3)
(0.8
)%
 
(10.6
)%
 
0.1
 %
 
(4.0
)%
Effective rate
(34.3
)%
 
25.2
 %
 
37.1
 %
 
33.9
 %
________________________
(1)
Relates primarily to lower tax rates on income attributable to international operations.
(2)
Represents a provision for nondeductible items.
(3)
Includes the effect of discrete items and reserves taken for a certain tax position adopted by the Company.
The Company’s subsidiary in Costa Rica is operating under a 100% tax holiday through December 31, 2018 and a 50% tax holiday for the subsequent four years. The impact of the tax holiday in Costa Rica for the three and nine months ended September 30, 2015 was immaterial.
The Company had gross unrecognized tax benefits, inclusive of penalties and interest, of $48.0 million and $44.4 million at September 30, 2015 and December 31, 2014, respectively, that, if recognized, would result in a net tax benefit of $16.0 million and $12.7 million as of September 30, 2015 and December 31, 2014, respectively. The increase in gross unrecognized tax benefits was due to an unrecognized tax benefit of $3.6 million associated with certain business combinations, which is included in “Other liabilities” in the Company’s condensed consolidated statements of financial condition.
During the three and nine months ended September 30, 2015, the Company did not provide for U.S. income taxes or foreign withholding taxes on the quarterly undistributed earnings from operations of its subsidiaries operating outside of the United States. Undistributed pre-tax income of these subsidiaries during the three and nine months ended September 30, 2015, was approximately $9.8 million and $18.3 million, respectively.