Income Taxes

12 Months Ended

Dec. 31, 2023

Income Tax Disclosure [Abstract]

Income Taxes

INCOME TAXES

Current and deferred provision for income taxes

Earnings before income taxes for the years ended December 31 were taxed within the following jurisdictions:

In millions	2023		2022		2021
United States	$	1,690.7	$	1,312.3	$	995.5
Non-U.S.	876.6		859.8		795.2
Total	$	2,567.3	$	2,172.1	$	1,790.7

The components of the Provision for income taxes for the years ended December 31 were as follows:

In millions	2023		2022		2021
Current tax expense (benefit):
United States	$	377.6	$	180.4	$	247.0
Non-U.S.	174.3		127.7		111.7
Total:	551.9		308.1		358.7
Deferred tax expense (benefit):
United States	(18.8)		66.5		(42.5)
Non-U.S.	(34.7)		1.3		17.3
Total:	(53.5)		67.8		(25.2)
Total tax expense (benefit):
United States	358.8		246.9		204.5
Non-U.S.	139.6		129.0		129.0
Total	$	498.4	$	375.9	$	333.5

The Provision for income taxes differs from the amount of income taxes determined by applying the applicable U.S. statutory income tax rate to pretax income, as a result of the following differences:

	Percent of pretax income
	2023		2022		2021
Statutory U.S. rate	21.0	%	21.0	%	21.0	%
Increase (decrease) in rates resulting from:
Non-U.S. tax rate differential	(1.9)		(2.8)		(2.8)
Tax on U.S. subsidiaries on non-U.S. earnings (a)	(0.4)		0.3		(0.3)
State and local income taxes (b)	3.2		1.1		2.0
Valuation allowances (c)	(1.2)		(0.7)		(1.1)
Stock based compensation	(1.2)		(0.8)		(1.8)
Other adjustments	(0.1)		(0.8)		1.6
Effective tax rate	19.4	%	17.3	%	18.6	%

(a)Net of foreign tax credits

(b)Net of changes in state valuation allowances

(c)Primarily federal and non-U.S., excludes state valuation allowances

Tax incentives, in the form of tax holidays, have been granted to the Company in certain jurisdictions to encourage industrial development. The expiration of these tax holidays varies by country. The tax holidays are conditional on the Company meeting certain employment and investment thresholds. The most significant tax holidays relate to the Company’s qualifying locations in China, Puerto Rico and Panama. The benefit for the tax holidays for the years ended December 31, 2023, 2022 and 2021 was $51.9 million, $52.5 million and $32.6 million, respectively.

Deferred tax assets and liabilities

A summary of the deferred tax accounts at December 31 were as follows:

In millions	2023		2022
Deferred tax assets:
Inventory and accounts receivable	$	11.8	$	11.2
Depreciable and amortizable assets	1.4		2.6
Operating lease liabilities	122.4		112.0
Postemployment and other benefit liabilities	239.2		254.6
Product liability	7.3		5.5
Other reserves and accruals	198.6		181.5
Net operating losses and credit carryforwards	287.4		346.0
Other	41.4		40.7
Gross deferred tax assets	909.5		954.1
Less: deferred tax valuation allowances	(164.0)		(199.8)
Deferred tax assets net of valuation allowances	$	745.5	$	754.3
Deferred tax liabilities:
Inventory and accounts receivable	$	(15.3)	$	(50.7)
Depreciable and amortizable assets	(1,073.2)		(1,069.0)
Operating lease right-of-use assets	(120.2)		(110.4)
Postemployment and other benefit liabilities	(13.0)		(15.7)
Other reserves and accruals	(2.2)		(5.5)
Undistributed earnings of foreign subsidiaries	(35.5)		(28.0)
Other	0.7		(1.6)
Gross deferred tax liabilities	(1,258.7)		(1,280.9)
Net deferred tax assets (liabilities)	$	(513.2)	$	(526.6)

At December 31, 2023, no deferred taxes have been provided for earnings of certain of the Company’s subsidiaries, since these earnings have been and under current plans will continue to be permanently reinvested in these subsidiaries. These earnings amount to approximately $700 million which if distributed would result in additional taxes, which may be payable upon distribution, of approximately $200 million.

At December 31, 2023, the Company had the following operating loss, capital loss and tax credit carryforwards available to offset taxable income in prior and future years:

In millions	Amount		Expiration Period
U.S. Federal net operating loss carryforwards	$	113.9	2024-Unlimited
U.S. Federal credit carryforwards	95.0		2026-2043
U.S. State net operating loss carryforwards	2,497.0		2024-Unlimited
U.S. State credit carryforwards	27.1		2024-Unlimited
Non-U.S. net operating loss carryforwards	477.3		2024-Unlimited
Non-U.S. credit carryforwards	17.3		Unlimited

The U.S. state net operating loss carryforwards were incurred in various jurisdictions. The non-U.S. net operating loss carryforwards were incurred in various jurisdictions, predominantly in Belgium, Brazil, Luxembourg, and Spain.

Activity associated with the Company’s valuation allowance is as follows:

In millions	2023		2022		2021
Beginning balance	$	199.8	$	258.6	$	320.5
Increase to valuation allowance	24.3		5.9		86.5
Decrease to valuation allowance	(57.8)		(65.1)		(113.5)
Write off against valuation allowance	(2.2)		—		(33.0)
Acquisition and purchase accounting	1.3		—		—
Accumulated other comprehensive income (loss)	(1.4)		0.4		(1.9)
Ending balance	$	164.0	$	199.8	$	258.6

During 2023, the Company recorded a net $30.3 million reduction in valuation allowances primarily related to deferred tax assets associated with both foreign tax credits and operations of international subsidiaries. Additional reductions in the valuation allowance related to deferred tax assets associated with foreign tax credits could be recognized in future periods if foreign source income exceeds current projections for the periods 2024 through 2027, the remainder of the carryforward period.

During 2022, the Company recorded a $48.2 million reduction in valuation allowances primarily related to certain net state deferred tax assets resulting from U.S. legal entity restructurings and deferred tax assets associated with foreign tax credits as a result of an increase in the 2022 year and projected foreign source income.

During 2021, the Company recorded a $21.4 million reduction in valuation allowance on deferred tax assets primarily related to foreign tax credits as a result of an increase in current year foreign source income.

Unrecognized tax benefits

The Company has total unrecognized tax benefits of $84.9 million and $82.4 million as of December 31, 2023, and December 31, 2022, respectively. The amount of unrecognized tax benefits that, if recognized, would affect the continuing operations effective tax rate are $43.6 million as of December 31, 2023. A reconciliation of the beginning and ending amount of unrecognized tax benefits is as follows:

In millions	2023		2022		2021
Beginning balance	$	82.4	$	65.2	$	65.4
Additions based on tax positions related to the current year	3.6		3.9		1.0
Additions based on tax positions related to prior years	0.6		22.5		5.1
Reductions based on tax positions related to prior years	(0.5)		(5.9)		(2.4)
Reductions related to settlements with tax authorities	(1.4)		(0.9)		(0.1)
Reductions related to lapses of statute of limitations	(1.0)		(0.6)		(1.0)
Translation (gain) loss	1.2		(1.8)		(2.8)
Ending balance	$	84.9	$	82.4	$	65.2

The Company records interest and penalties associated with the uncertain tax positions within its Provision for income taxes. The Company had reserves associated with interest and penalties, net of tax, of $16.0 million and $11.3 million at December 31, 2023 and December 31, 2022, respectively. For the years ended December 31, 2023 and December 31, 2022, the Company recognized $0.2 million and $3.7 million tax expense, respectively, in interest and penalties, net of tax in continuing operations related to these uncertain tax positions.

The total amount of unrecognized tax benefits relating to the Company's tax positions is subject to change based on future events including, but not limited to, the settlements of ongoing audits and/or the expiration of applicable statutes of limitations. Although the outcomes and timing of such events are highly uncertain, it is reasonably possible that the balance of gross unrecognized tax benefits, excluding interest and penalties, could potentially be reduced by up to approximately $35 million during the next 12 months.

The provision for income taxes involves a significant amount of management judgment regarding interpretation of relevant facts and laws in the jurisdictions in which the Company operates. Future changes in applicable laws, projected levels of taxable income and tax planning could change the effective tax rate and tax balances recorded by the Company. In addition, tax authorities periodically review income tax returns filed by the Company and can raise issues regarding its filing positions, timing and amount of income or deductions, and the allocation of income among the jurisdictions in which the Company operates. A significant period of time may elapse between the filing of an income tax return and the ultimate resolution of an issue raised by a revenue authority with respect to that return. In the normal course of business the Company is subject to examination by taxing authorities throughout the world, including such major jurisdictions as Belgium, Brazil, Canada, China, France, Germany, Ireland, Italy, Luxembourg, Mexico, Singapore, Spain, the Netherlands, the United Kingdom and the United States. These examinations on their own, or any subsequent litigation related to the examinations, may result in additional taxes or penalties against the Company. If the ultimate result of these audits differ from original or adjusted estimates, they could have a material impact on the Company’s income tax provision. In general, the examination of the Company’s U.S. federal tax returns is complete or effectively settled for years prior to 2016. The Company’s U.S. federal income tax returns for 2016 to 2019 are currently under examination by the Internal Revenue Service (IRS). In general, the examination of the Company’s material non-U.S. income tax returns is complete or effectively settled for the years prior to 2013, with certain matters prior to 2013 being resolved through appeals and litigation and also unilateral procedures as provided for under double tax treaties.

On December 18, 2023, Ireland enacted legislation related to the 15% minimum tax element of the Organisation for Economic Co-operation and Development's (OECD) tax reform initiative, commonly referred to as “Pillar Two”, effective January 1, 2024. The Company is continuing to evaluate the potential impacts of proposed and enacted legislative changes as new guidance becomes available. The legislation does not impact the Company's 2023 effective tax rate.