Income Taxes (Tables)
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12 Months Ended |
Dec. 31, 2016 |
Income Tax Disclosure [Abstract] |
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Schedule of Domestic and Foreign Components of Loss from Continuing Operations before Income Taxes |
The components of our earnings (loss) from continuing operations before income taxes are as follows: | | | | | | | | | | | | | | | | Year ended December 31, | | 2016 | | 2015 | | 2014 | | in millions | | | | | | | U.K. | $ | 930.7 |
| | $ | 778.1 |
| | $ | 585.7 |
| U.S. | (848.5 | ) | | (924.5 | ) | | (1,105.6 | ) | Switzerland | 274.6 |
| | 395.3 |
| | 326.1 |
| The Netherlands | 127.4 |
| — |
| (1,353.3 | ) | — |
| (644.5 | ) | Germany | (49.3 | ) | | (5.1 | ) | | (294.7 | ) | Chile | 47.4 |
| | 182.3 |
| | 43.1 |
| Panama | 19.4 |
| | — |
| | — |
| Belgium | 13.7 |
| — |
| 175.4 |
| — |
| 21.5 |
| Other | 34.0 |
| | 67.2 |
| | 12.5 |
| Total | $ | 549.4 |
| | $ | (684.6 | ) | | $ | (1,055.9 | ) |
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Schedule Of Income Tax Expense Benefit |
Income tax benefit (expense) consists of: | | | | | | | | | | | | | | Current | | Deferred | | Total | | in millions | Year ended December 31, 2016: | | | | | | The Netherlands | $ | (0.4 | ) | | $ | 1,315.3 |
| | $ | 1,314.9 |
| U.S. (a) | 146.9 |
| | 88.3 |
| | 235.2 |
| Chile | (134.3 | ) | | (11.2 | ) | | (145.5 | ) | Belgium | (105.0 | ) | | 57.0 |
| | (48.0 | ) | Switzerland | (48.5 | ) | | 5.3 |
| | (43.2 | ) | Germany | (77.9 | ) | | 41.0 |
| | (36.9 | ) | Panama | (18.6 | ) | | 14.1 |
| | (4.5 | ) | U.K. | (15.3 | ) | | 17.0 |
| | 1.7 |
| Other | (49.0 | ) | | (6.8 | ) | | (55.8 | ) | Total | $ | (302.1 | ) | | $ | 1,520.0 |
| | $ | 1,217.9 |
| | | | | | | Year ended December 31, 2015: | | | | | | U.K | $ | (0.9 | ) | | $ | (208.5 | ) | | $ | (209.4 | ) | The Netherlands | 2.5 |
| | 159.0 |
| | 161.5 |
| Belgium | (125.4 | ) | | 11.1 |
| | (114.3 | ) | Switzerland | (63.2 | ) | | (14.7 | ) | | (77.9 | ) | Chile | (57.4 | ) | | 13.5 |
| | (43.9 | ) | Germany | (66.7 | ) | | 24.3 |
| | (42.4 | ) | U.S. (a) | (81.2 | ) | | 58.7 |
| | (22.5 | ) | Other | (22.7 | ) | | 6.7 |
| | (16.0 | ) | Total | $ | (415.0 | ) | | $ | 50.1 |
| | $ | (364.9 | ) | | | | | | | Year ended December 31, 2014: | | | | | | Continuing operations: | | | | | | U.K. | $ | (2.1 | ) | | $ | 113.4 |
| | $ | 111.3 |
| U.S. (a) | (22.5 | ) | | 129.6 |
| | 107.1 |
| Belgium | (138.7 | ) | | 31.7 |
| | (107.0 | ) | Switzerland | (76.8 | ) | | 3.1 |
| | (73.7 | ) | The Netherlands | 11.1 |
| | 42.5 |
| | 53.6 |
| Germany | (22.6 | ) | | 37.0 |
| | 14.4 |
| Chile | 17.1 |
| | (24.1 | ) | | (7.0 | ) | Other | (41.1 | ) | | 17.4 |
| | (23.7 | ) | Total — continuing operations | $ | (275.6 | ) | | $ | 350.6 |
| | $ | 75.0 |
| Discontinued operation | $ | — |
| | $ | (0.1 | ) | | $ | (0.1 | ) |
_______________
(a) Includes federal and state income taxes. Our U.S. state income taxes were not material during any of the years presented.
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Income Tax Benefit (Expense) Reconciliation |
Income tax benefit (expense) attributable to our earnings (loss) from continuing operations before income taxes differs from the amounts computed using the applicable income tax rate as a result of the following factors: | | | | | | | | | | | | | | Year ended December 31, | | 2016 | | 2015 | | 2014 | | in millions | | | | | | | Computed “expected” tax benefit (expense) (a) | $ | (109.9 | ) | | $ | 136.9 |
| | $ | 221.7 |
| Change in valuation allowances (b): | | | | | | Benefit | 1,149.1 |
| | 6.8 |
| | 11.9 |
| Expense | (260.4 | ) | | (508.3 | ) | | (373.1 | ) | Recognition of previously unrecognized tax benefits | 212.5 |
| | 44.4 |
| | 29.5 |
| Non-deductible or non-taxable foreign currency exchange results (b): | | | | | | Benefit | 228.0 |
| | 53.2 |
| | 71.9 |
| Expense | (34.3 | ) | | (5.1 | ) | | (16.3 | ) | Tax effect of intercompany financing | 173.7 |
| | 154.9 |
| | 166.9 |
| Non-deductible or non-taxable interest and other expenses (b): | | | | | | Expense | (234.9 | ) | | (106.6 | ) | | (236.5 | ) | Benefit | 63.8 |
| | 48.1 |
| | 58.0 |
| Enacted tax law and rate changes (c) | (162.2 | ) | | (280.5 | ) | | 23.9 |
| International rate differences (b) (d): | | | | | | Benefit | 138.1 |
| | 200.8 |
| | 266.4 |
| Expense | (43.0 | ) | | (52.7 | ) | | (27.6 | ) | Basis and other differences in the treatment of items associated with investments in subsidiaries and affiliates (b): | | | | | | Benefit | 173.6 |
| | 3.3 |
| | 32.6 |
| Expense | (110.8 | ) | | (96.9 | ) | | (168.0 | ) | Other, net | 34.6 |
| | 36.8 |
| | 13.7 |
| Total income tax benefit (expense) | $ | 1,217.9 |
| | $ | (364.9 | ) | | $ | 75.0 |
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_______________
| | (a) | The statutory or “expected” tax rates are the U.K. rates of 20.0% for 2016 and 2015 and 21.0% for 2014. |
| | (b) | Country jurisdictions giving rise to income tax benefits are grouped together and shown separately from country jurisdictions giving rise to income tax expenses. |
| | (c) | During 2015, the U.K. enacted legislation that will change the corporate income tax rate from the current rate of 20.0% to 19.0% in April 2017 and 18.0% in April 2020. Substantially all of the impact of these rate changes on our deferred tax balances was recorded in the fourth quarter of 2015 when the change in law was enacted. During the third quarter of 2016, the U.K. enacted legislation that will further reduce the corporate income tax rate in April 2020 from 18.0% to 17.0%. Substantially all of the impact of this rate change on our deferred tax balances was recorded during the third quarter of 2016. |
(d) Amounts reflect adjustments (either a benefit or expense) to the “expected” tax benefit (expense) for statutory rates in jurisdictions in which we operate outside of the U.K.
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Schedule Of Current And Noncurrent Deferred Tax Assets And Liabilities |
The components of our deferred tax assets are as follows: | | | | | | | | | | December 31, | | 2016 | | 2015 | | in millions | | | | | Deferred tax assets (a) | $ | 3,024.7 |
| | $ | 2,342.9 |
| Deferred tax liabilities (a) | (1,307.8 | ) | | (1,785.7 | ) | Net deferred tax asset | $ | 1,716.9 |
| | $ | 557.2 |
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_______________
| | (a) | Our deferred tax assets and liabilities are included in other assets, net and other long-term liabilities, respectively, in our consolidated balance sheets. |
The tax effects of temporary differences that give rise to significant portions of the deferred tax assets and deferred tax liabilities are presented below: | | | | | | | | | | December 31, | | 2016 | | 2015 | | in millions | Deferred tax assets: | | | | Net operating loss and other carryforwards | $ | 6,598.0 |
| | $ | 5,873.2 |
| Property and equipment, net | 2,028.9 |
| | 2,583.1 |
| Debt | 1,626.3 |
| | 1,611.7 |
| Intangible assets | 99.5 |
| | 112.4 |
| Derivative instruments | 68.3 |
| | 173.1 |
| Other future deductible amounts | 399.6 |
| | 272.5 |
| Deferred tax assets | 10,820.6 |
| | 10,626.0 |
| Valuation allowance | (6,015.4 | ) | | (6,395.6 | ) | Deferred tax assets, net of valuation allowance | 4,805.2 |
| | 4,230.4 |
| Deferred tax liabilities: | | | | Property and equipment, net | (1,076.9 | ) | | (1,053.4 | ) | Intangible assets | (901.6 | ) | | (1,826.5 | ) | Investments (including consolidated partnerships) | (485.9 | ) | | (374.5 | ) | Derivative instruments | (175.5 | ) | | (280.7 | ) | Other future taxable amounts | (448.4 | ) | | (138.1 | ) | Deferred tax liabilities | (3,088.3 | ) | | (3,673.2 | ) | Net deferred tax asset | $ | 1,716.9 |
| | $ | 557.2 |
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Summary of Operating Loss Carryforwards |
The significant components of our tax loss carryforwards and related tax assets at December 31, 2016 are as follows: | | | | | | | | | | | | Country | | Tax loss carryforward | | Related tax asset | | Expiration date | | in millions | | | U.K.: | | | | | | Amount attributable to capital losses | $ | 20,335.9 |
| | $ | 3,457.1 |
| | Indefinite | Amount attributable to net operating losses | 2,563.4 |
| | 435.8 |
| | Indefinite | The Netherlands | 4,108.7 |
| | 1,027.2 |
| | 2017-2025 | Germany | 1,608.1 |
| | 259.5 |
| | Indefinite | U.S. | 1,268.0 |
| | 320.1 |
| | 2019-2036 | Luxembourg | 1,124.1 |
| | 292.4 |
| | Indefinite | Belgium | 894.2 |
| | 303.9 |
| | Indefinite | Barbados | 817.9 |
| | 52.4 |
| | 2017 - 2023 | Ireland | 601.9 |
| | 75.2 |
| | Indefinite | France | 505.4 |
| | 146.2 |
| | Indefinite | Jamaica | 449.7 |
| | 149.9 |
| | Indefinite | Hungary | 166.8 |
| | 15.0 |
| | 2020-2025 | Other | 264.9 |
| | 63.3 |
| | Various | Total | $ | 34,709.0 |
| | $ | 6,598.0 |
| | |
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Unrecognized Tax Benefits Roll Forward |
The changes in our unrecognized tax benefits are summarized below: | | | | | | | | | | | | | | 2016 | | 2015 | | 2014 | | in millions | | | | | | | Balance at January 1 | $ | 609.9 |
| | $ | 513.5 |
| | $ | 490.9 |
| Reductions for tax positions of prior years | (184.2 | ) | | (42.2 | ) | | (50.2 | ) | Additions for tax positions of prior years | 112.9 |
| | 27.0 |
| | 64.5 |
| Lapse of statute of limitations | (84.6 | ) | | (8.3 | ) | | (1.9 | ) | Effects of business acquisitions | 38.0 |
| | — |
| | — |
| Additions based on tax positions related to the current year | 33.5 |
| | 142.3 |
| | 38.2 |
| Foreign currency translation | (10.9 | ) | | (22.3 | ) | | (27.0 | ) | Settlements with tax authorities | (13.5 | ) | | (0.1 | ) | | (1.0 | ) | Balance at December 31 | $ | 501.1 |
| | $ | 609.9 |
| | $ | 513.5 |
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