Income Taxes (Tables)

12 Months Ended

Dec. 31, 2020

Income Tax Disclosure [Abstract]

Schedule of income before income tax and components of Income tax expense (benefit)

Pre-tax income (loss) and the (benefit) provision for income taxes from continuing operations are summarized as follows (in millions):

	Year Ended
	December 31, 2020		December 31, 2019		December 31, 2018
Pre-tax income (loss):
Ireland	$	(411.8)	$	(300.3)	$	(109.0)
United States	147.3		(291.9)		(428.6)
Other foreign	115.1		763.2		828.2
Total pre-tax income (loss)	(149.4)		171.0		290.6
Current provision (benefit) for income taxes:
Ireland	2.7		(2.2)		22.7
United States	17.6		51.0		66.4
Other foreign	47.4		16.1		75.1
Subtotal	67.7		64.9		164.2
Deferred provision (benefit) for income taxes:
Ireland	(0.1)		—		(13.9)
United States	(52.3)		(30.2)		7.3
Other foreign	(2.1)		(9.8)		2.0
Subtotal	(54.5)		(40.0)		(4.6)
Total provision for income taxes	$	13.2	$	24.9	$	159.6

Schedule of effective income tax rate reconciliation

A reconciliation of the provision based on the Irish statutory income tax rate to our effective income tax rate is as follows:

	Year Ended
	December 31, 2020		December 31, 2019		December 31, 2018
Provision at statutory rate	12.5	%	12.5	%	12.5	%
Foreign rate differential	14.9		3.1		(7.1)
State income taxes, net of federal benefit	(6.2)		2.7		3.0
Provision to return	(1.2)		0.8		(1.0)
Tax credits	8.8		(2.7)		(1.3)
Change in tax law	(1.8)		(1.1)		(6.2)
Change in valuation allowance	52.0		(29.1)		51.0
Change in unrecognized taxes	(28.8)		(4.7)		13.8
Permanent differences	(70.7)		31.2		(14.1)
Legal entity restructuring	21.1		—		—
Taxes on unremitted earnings	(8.8)		3.6		3.9
Other	(0.6)		(1.7)		0.4
Effective income tax rate	(8.8)	%	14.6	%	54.9	%

Schedule of deferred tax assets and liabilities

The components of our net deferred income tax asset (liability) were as follows (in millions):

    

	Year Ended
	December 31, 2020		December 31, 2019
Deferred income tax asset (liability):
Depreciation and amortization	$	(393.7)	$	(366.7)
Investment in partnership	—		(38.1)
Right of use assets	(44.3)		(30.5)
Unremitted earnings	(42.0)		(29.0)
Inventory basis differences	27.7		32.7
Accrued liabilities	81.4		91.3
Lease obligations	45.3		30.5
Share-based compensation	24.5		23.2
Federal benefit of unrecognized tax positions	23.5		20.7
Loss and credit carryforwards	390.1		373.3
R&D credit carryforwards	48.4		54.1
Interest carryforwards	17.9		60.5
Other, net	0.9		4.1
Subtotal	$	179.7	$	226.1
Valuation allowance (1)	(414.8)		(501.3)
Net deferred income tax liability	$	(235.1)	$	(275.2)

(1) The movement in the valuation allowance balance differs from the amount in the effective tax rate reconciliation due to adjustments affecting balance sheet only items and foreign currency.

    The above amounts are classified on the Consolidated Balance Sheets as follows (in millions):

	Year Ended
	December 31, 2020		December 31, 2019
Assets	$	44.2	$	5.4
Liabilities	(279.3)		(280.6)
Net deferred income tax liability	$	(235.1)	$	(275.2)

The change in valuation allowance reducing deferred taxes was (in millions):

	Year Ended
	December 31, 2020		December 31, 2019
Balance at beginning of period	$	501.3	$	557.9
Change in assessment (1)	(50.3)		(8.3)
Current year operations, foreign currency and other	(36.2)		(48.3)
Balance at end of period	$	414.8	$	501.3

(1) Includes release of $51.5 million of valuation allowance against U.S. deferred tax assets in 2020.

Summary of income tax contingencies

The Company operates in multiple jurisdictions with complex tax policy and regulatory environments and establishes reserves for uncertain tax positions in accordance with the accounting guidance governing uncertainty in income taxes. Uncertainty in a tax position may arise because tax laws are subject to interpretation. The following table summarizes the activity related to the liability recorded for uncertain tax positions, excluding interest and penalties (in millions):

	Unrecognized Tax Benefits
Balance at December 31, 2018	$	377.1
Additions:
Positions related to the current year	8.2
Positions related to prior years	3.1
Reductions:
Settlements with taxing authorities	(3.0)
Lapse of statutes of limitation	(23.5)
Decrease in prior year positions	(12.1)
Cumulative translation adjustment	0.7
Balance at December 31, 2019	350.5
Additions:
Positions related to the current year	18.2
Positions related to prior years	28.9
Reductions:
Lapse of statutes of limitation	(2.2)
Decrease in prior year positions	(1.0)
Cumulative translation adjustment	1.6
Balance at December 31, 2020	$	396.0