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Income Taxes
6 Months Ended
Jul. 02, 2016
Income Tax Disclosure [Abstract]  
Income Taxes
INCOME TAXES
As of July 2, 2016, the Company had $405 million accrued for uncertain tax positions, all of which would affect the Company’s effective tax rate if recognized. Additionally, the Company had $56 million accrued for gross interest and penalties as of July 2, 2016. At January 2, 2016, the liability for uncertain tax positions was $338 million and the accrual for gross interest and penalties was $58 million.
The Company is subject to U.S. federal income tax as well as income tax of multiple state and foreign jurisdictions. The Company has substantially concluded all material U.S. federal, state, foreign and local income tax matters for all tax years through 2004. In April 2015, the U.S. Internal Revenue Service (IRS) completed an audit of the Company’s 2010 and 2011 tax returns and proposed adjustments in an audit report. In February 2014, the IRS completed an audit of the Company’s 2008 and 2009 tax returns and also proposed adjustments in an audit report.

The Company's effective income tax rate was 11.9% and 4.1% for the second quarter of 2016 and 2015, respectively, and 18.0% and 10.6% for the six months ended during 2016 and 2015, respectively. The Company’s effective income tax rate differs from the U.S. federal statutory rate each year due to certain operations that are subject to tax incentives, state and local taxes and foreign taxes that are different than the U.S. federal statutory rate. In addition, the effective tax rate can be impacted each period by discrete income tax factors and events. During the three months ended July 2, 2016, special charges, acquisition-related costs and discrete income tax items favorably impacted the effective income tax rate by 1.5 percentage points. During the six months ended July 2, 2016, special charges, acquisition-related costs, other-than-temporary impairments and discrete income tax items unfavorably impacted the effective income tax rate by 5.1 percentage points. Special charges, acquisition-related costs and discrete income tax items recognized during the second quarter and first six months of 2015 favorably impacted the effective rate by 13.2 percentage points and 6.5 percentage points, respectively.

During the first quarter of 2016, the European Commission concluded that decisions by the tax authorities in Belgium regarding corporate income taxes paid under certain excess profit rulings, including the ruling previously granted to one of the Company’s subsidiaries, did not comply with European Union rules on state aid. Based on the applicability of this conclusion to the Company's 2009 through 2014 tax returns in Belgium, the Company recorded a liability of 46 million Euros including interest during the first quarter of 2016 to reserve for this uncertain tax position. During the second quarter of 2016, the Company revised the estimated liability to 43 million Euros ($48 million as of July 2, 2016) including interest.