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Income Taxes
9 Months Ended
Sep. 30, 2015
Income Tax Disclosure [Abstract]  
Income Taxes
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, 2015, the Company recorded an income tax benefit from continuing operations of $54.0 million on a pre-tax loss from continuing operations of $78.6 million. For the three months ended September 30, 2014, the Company recorded an income tax benefit from continuing operations of $6.4 million on a pre-tax loss from continuing operations of $19.0 million.
For the nine months ended September 30, 2015, the Company recorded an income tax benefit from continuing operations of $42.9 million on a pre-tax loss from continuing operations of $99.5 million. For the nine months ended September 30, 2014, the Company recorded income tax expense from continuing operations of $20.2 million on a pre-tax loss from continuing operations of $24.9 million.
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, 2015 and 2014 included losses from continuing operations 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, nondeductible stock-based compensation expense and decreases in liabilities for uncertain tax positions.
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. The Company decreased its liabilities for uncertain tax positions and recognized income tax benefits of $17.8 million and $7.7 million for the three months ended September 30, 2015 and 2014, respectively, 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, 2015, the Company believes that it is reasonably possible that changes of up to $5.5 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.
On July 27, 2015, in Altera Corp. v. Commissioner, the U.S. Tax Court issued an opinion related to the treatment of stock-based compensation expense in an intercompany cost-sharing arrangement. At this time, the U.S. Department of the Treasury has not withdrawn the requirement to include stock-based compensation from its regulations. Based on the Company's review of this matter and its intercompany cost-sharing agreements, it has concluded that an income tax benefit relating to prior period intercompany charges that may ultimately be reversed under its intercompany cost-sharing agreements does not meet the criteria for recognition in its consolidated financial statements as of September 30, 2015. The Company will continue to monitor ongoing developments with respect to the Altera case and the related IRS regulations in future periods and if the Company determines that the recognition criteria are met in a subsequent period, an income tax benefit of approximately $14.0 million would be recognized at that time.
As of September 30, 2015 and December 31, 2014, unamortized tax effects of intercompany transactions of $1.0 million and $14.2 million, respectively, are included within "Prepaid expenses and other current assets" on the condensed consolidated balance sheets. As of September 30, 2015, the estimated future amortization of the tax effects of intercompany transactions is $1.0 million for the remainder of 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.     
See Note 2, "Discontinued Operations and Other Dispositions," for discussion of the income tax provision (benefit) from discontinued operations for the three and nine months ended September 30, 2015 and 2014.