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Income Taxes
9 Months Ended
Sep. 30, 2014
Income Tax Disclosure [Abstract]  
Income Tax Disclosure [Text Block]
INCOME TAXES
The Company's tax provision for interim periods is determined using an estimate of its annual effective tax rate, adjusted for discrete items.
For the three months ended September 30, 2014, the Company recorded an income tax benefit of $6.4 million on pre-tax losses of $25.5 million, for an effective tax rate of 25.3%. For the three months ended September 30, 2013, the Company recorded income tax expense of $15.9 million on pre-tax income of $14.6 million, for an effective tax rate of 108.8%.
For the nine months ended September 30, 2014, the Company recorded income tax expense of $20.2 million on pre-tax losses of $55.1 million, for an effective tax rate of (36.6)%. For the nine months ended September 30, 2013, the Company recorded income tax expense of $62.7 million on pre-tax income of $52.6 million, for an effective tax rate of 119.2%.
The Company's U.S. statutory rate is 35%. Significant factors impacting the effective tax rate for the three and nine months ended September 30, 2014 and 2013 included losses in jurisdictions that the Company is not able to benefit due to uncertainty as to the realization of those losses, amortization of the tax effects of intercompany sales of intellectual property and nondeductible stock-based compensation expense. Additionally, the effective tax rate for the three and nine months ended September 30, 2014 included a $7.7 million decrease to the Company's liabilities for uncertain tax positions, as discussed in the following paragraph.
The Company is currently undergoing income tax audits in multiple jurisdictions. There are many factors, including factors outside of the Company's control, which influence the progress and completion of these audits. For the three and nine months ended September 30, 2014, the Company decreased its liabilities for uncertain tax positions and income tax expense by $7.7 million as a result of new information that impacted its estimates of amounts that are more-likely-than not of being realized upon ultimate settlement. As of September 30, 2014, the Company believes that it is reasonably possible that additional changes of up to $35.5 million in unrecognized tax benefits may occur within the next 12 months upon closing of income tax audits or the expiration of applicable statutes of limitations.
As of September 30, 2014, unamortized tax effects of intercompany transactions of $23.4 million and $1.5 million are included within "Prepaid expenses and other current assets" and "Other non-current assets," respectively, on the condensed consolidated balance sheet. As of December 31, 2013, unamortized tax effects of intercompany transactions of $28.5 million and $20.4 million are included within "Prepaid expenses and other current assets" and "Other non-current assets," respectively, on the condensed consolidated balance sheet. As of September 30, 2014, the estimated future amortization of the tax effects of intercompany transactions is $6.2 million for the remainder of 2014 and $18.7 million for 2015. These amounts exclude the benefits, if any, for tax deductions in other jurisdictions that the Company may be entitled to as a result of the related intercompany transactions.