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INCOME TAXES
 12 Months Ended
Dec. 31, 2023
Income Tax Disclosure [Abstract]  
INCOME TAXES INCOME TAXES
Components of income (loss) from continuing operations before income taxes - U.S. and outside U.S. components of income (loss) from continuing operations before income taxes were as follows:
 Year Ended December 31,
(In millions)202320222021
United States$15.2 $(148.8)$(288.2)
Outside United States191.3 217.7 486.3 
Income (loss) from continuing operations before income taxes$206.5 $68.9 $198.1 

Provision for income tax - The provision for income taxes consisted of:
 Year Ended December 31,
(In millions)202320222021
Current
United States$7.3 $(0.5)$0.2 
Outside United States201.6 118.9 206.0 
Total current income taxes208.9 118.4 206.2 
Deferred
Outside United States(54.2)(13.0)(95.1)
Total deferred income taxes(54.2)(13.0)(95.1)
Provision for income taxes$154.7 $105.4 $111.1 
Deferred tax assets and liabilities - Significant components of deferred tax assets and liabilities were as follows: 
 December 31,
(In millions)20232022
Deferred tax assets attributable to
Accrued expenses$184.3 $166.8 
Capital loss21.1 21.1 
Non-deductible interest96.4 87.7 
Foreign tax credit carryforwards120.4 136.5 
Other tax credits168.0 159.2 
Net operating loss carryforwards484.8 487.5 
Research and development credit23.3 13.7 
Foreign exchange— 21.7 
Provisions for pensions and other long-term employee benefits33.5 23.5 
Contingencies54.0 45.3 
Leases208.2 208.9 
Other11.1 6.4 
Deferred tax assets1,405.1 1,378.3 
Valuation allowance(917.4)(999.1)
Deferred tax assets, net of valuation allowance487.7 379.2 
Deferred tax liabilities attributable to
Contract liabilities24.7 23.1 
Tax on undistributed earnings not indefinitely reinvested60.0 13.4 
Property, plant and equipment, intangibles and other assets81.2 117.2 
Foreign exchange41.0 — 
Leases203.8 203.5 
Other4.4 5.0 
Deferred tax liabilities415.1 362.2 
Net deferred tax assets$72.6 $17.0 

At December 31, 2023 and 2022, the carrying amount of net deferred tax assets and the related valuation allowance included the impact of foreign currency translation adjustments.
Non-deductible interest. At December 31, 2023, deferred tax assets include tax benefits related to certain intercompany interest costs which are not currently deductible, but which may be deductible in future periods. If not utilized, these costs will become permanently non-deductible beginning in 2025. Management believes that it is more likely than not that we will not be able to deduct these costs before expiration of the carry forward period; therefore, we have established an uncertain tax position and valuation allowance against the related deferred tax assets.
Foreign tax credit carryforwards. At December 31, 2023, deferred tax assets included U.S. foreign tax credit carryforwards of $120.4 million, which, if not utilized, will begin to expire in 2024. Realization of these deferred tax assets is dependent on the generation of sufficient U.S. taxable income prior to the above date. Based on long-term forecasts of operating results, management believes that it is more likely than not that our U.S. earnings over the forecast period will not result in sufficient U.S. taxable income to fully realize these deferred tax assets; therefore, we have established a valuation allowance against the related deferred tax assets. In its analysis, management has considered the effect of deemed dividends and other expected adjustments to U.S. earnings that are required in determining U.S. taxable income. Non-U.S. earnings subject to U.S. tax, including deemed dividends for U.S. tax purposes, were $0.8 million in 2023, $0.3 million in 2022 and $19.5 million in 2021.
Net operating loss carryforwards. At December 31, 2023, we had $484.8 million of tax-effected net operating loss carryforwards, with approximately $20.1 million estimated to be utilized against our unrecognized tax benefits. The ultimate realization of these deferred tax assets depends on our ability to generate sufficient taxable income in the appropriate taxing jurisdiction. Our deferred tax assets from net operating losses will expire as follows:
(In millions)Net Operating Loss
2024 – 2027$27.1 
2028 – 2032116.8 
2033 – 204336.8 
Non-Expiring304.1 
$484.8 

Unrecognized tax benefits - The following table presents a summary of changes in our unrecognized tax benefits: 
(In millions)Federal, State and
Foreign Tax
Balance at December 31, 2021$68.8 
Reductions for tax positions related to prior years(22.8)
Additions for tax positions related to current year16.8 
Additions for tax positions due to settlements0.8 
Balance at December 31, 202263.6 
Reductions for tax positions related to prior years(19.1)
Additions for tax positions related to current year25.1 
Reductions for tax positions due to settlements(3.5)
Balance at December 31, 2023$66.1 

The amounts reported above for uncertain tax positions excludes interest and penalties of $2.8 million, $1.1 million, and $0.2 million for the years ended December 31, 2023, 2022, and 2021, respectively. Interest and penalties relating to these uncertain tax positions were included in income tax expense in our consolidated statements of income. It is reasonably possible that within twelve months, $6.9 million of assets for unrecognized tax benefits will be settled. This amount is reflected in income taxes payable; the remaining balance of the unrecognized tax benefit is recorded in other long-term liabilities. As of December 31, 2023, a net $43.9 million unrecognized tax benefit, without a net operating loss carryforward or other deferred tax asset to offset, would positively impact the effective tax rate and be recognized as additional tax benefits in our statement of operations if resolved in our favor.
We operate in numerous jurisdictions around the world and could be subject to multiple tax audits at any given time. Most notably, the following tax years and thereafter remain subject to examination: 2014 for Norway, 2022 for Nigeria, 2019 for Brazil, 2021 for France, 2019 for United States, and 2021 for United Kingdom.
TechnipFMC plc is a public limited company incorporated under the laws of England and Wales. Therefore, our earnings are subject to the U.K. statutory rate which is 25.0% effective April 2023, and 19.0% for both 2022 and 2021. Deferred taxes for the U.K. were revalued in 2021 when the law was enacted.
Effective income tax rate reconciliation - The effective income tax rate was different from the statutory U.K. income tax rate due to the following:
 Year Ended December 31,
 202320222021
Statutory income tax rate25.0 %19.0 %19.0 %
Net difference resulting from
Foreign earnings subject to different tax rates70.1 %114.0 %24.4 %
Adjustments to prior year taxes34.2 %(56.5)%(52.4)%
Net change in unrecognized tax benefits(0.1)%7.4 %12.3 %
Changes in valuation allowance(53.1)%100.1 %65.4 %
Deferred tax asset/liability revaluation for tax rate change(0.6)%(29.0)%(12.2)%
Other(0.6)%(1.9)%(0.4)%
Effective income tax rate74.9 %153.1 %56.1 %
(1) In 2023 our effective tax rate had a (53.1%) benefit related to changes in valuation allowances. This primarily was related to the release of a valuation allowance in Brazil based on the weight of positive evidence demonstrating the ability to realize its deferred tax assets, which are primarily indefinite-lived net operating losses. Our effective tax rate also shows an expense of 34.2% related to adjustments to prior year taxes. This amount includes expenses associated with expiring tax attributes. These tax attributes were fully valued, and the valuation allowance movement and attributed expirations are shown gross in the effective tax rate table above. The expiration did not have a net impact on tax expense.

Income tax holidays. We did not benefit from income tax holidays in 2023.