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Income Taxes
12 Months Ended
Dec. 31, 2013
Income Tax Disclosure [Abstract]  
INCOME TAXES
INCOME TAXES

The following table presents components of (loss) income from continuing operations before income taxes for the years ended December 31:
 
2013
 
2012
 
2011
Domestic
$
(171,878
)
 
$
(37,910
)
 
$
16,173

Foreign
52,071

 
148,805

 
142,764

Total
$
(119,807
)
 
$
110,895

 
$
158,937












The following table presents the components of income tax expense from continuing operations for the years ended December 31:
 
2013
 
2012
 
2011
Current:
 
 
 
 
 
U.S. Federal
$
10,453

 
$
3,381

 
$
(921
)
Foreign
59,481

 
39,185

 
41,244

State and local
3,231

 
2,006

 
932

Total current
73,165

 
44,572

 
41,255

Deferred:
 
 
 
 
 
U.S. Federal
(20,180
)
 
(2,344
)
 
9,727

Foreign
9,678

 
(13,159
)
 
(40,105
)
State and local
(5,948
)
 
(844
)
 
(2,849
)
Total deferred
(16,450
)
 
(16,347
)
 
(33,227
)
Income tax expense
$
56,715

 
$
28,225

 
$
8,028



In addition to the income tax expense listed above for the years ended December 31, 2013, 2012 and 2011, income tax expense (benefit) allocated directly to shareholders equity for the same periods was $67,351, $(8,909) and $(23,695), respectively. Offsetting the income tax expense allocated directly to shareholders equity for the year ended December 31, 2013 was a benefit of $9,049 related to current year movement in valuation allowance.

Income tax expense attributable to (loss) income from continuing operations differed from the amounts computed by applying the U.S. federal income tax rate of 35 percent to pretax (loss) income from continuing operations. The following table presents these differences for the years ended December 31:
 
2013
 
2012
 
2011
Statutory tax (benefit) expense
$
(41,932
)
 
$
38,813

 
$
55,628

Brazil nontaxable incentive
(7,849
)
 
(10,622
)
 
(10,652
)
Valuation allowance
43,884

 
1,609

 
(35,650
)
Brazil tax goodwill amortization
(3,807
)
 
(4,802
)
 
(5,231
)
Foreign tax rate differential
(12,432
)
 
(14,332
)
 
(10,946
)
Previously undistributed subsidiary earnings
59,460

 
10,648

 
10,724

Accrual adjustments
5,755

 
494

 
(2,584
)
Non-deductible goodwill
5,189

 

 

FCPA provision, nondeductible portion
5,412

 
2,939

 
1,563

Other
3,035

 
3,478

 
5,176

Income tax expense
$
56,715

 
$
28,225

 
$
8,028


In the second quarter of 2013, the Company recorded a valuation allowance for the Brazil manufacturing subsidiary due to a change in circumstances including lower profitability in core operations, lower anticipated taxable income and an unfavorable business outlook. The Company also changed its assertion regarding the indefinite reinvestment of foreign subsidiary earnings due primarily to forecasted cash needs within the United States and strategic decisions related to the Company’s capital structure. As a result, the Company recorded current and deferred tax expense (net of related foreign tax credits) due to the repatriation of earnings of approximately $55,000. In 2011 The Company released a valuation allowance for the Brazil manufacturing subsidiary related to a change in circumstances including sustained profitability in core operations and a favorable outlook.







The Company recognizes the benefit of tax positions taken or expected to be taken in its tax returns in the consolidated financial statements when it is more likely than not that the position will be sustained upon examination by authorities. Recognized tax positions are measured at the largest amount of benefit that is greater than fifty percent likely of being realized upon settlement.
Details of the unrecognized tax benefits are as follows:
 
2013
 
2012
Balance at January 1
$
13,178

 
$
12,636

Increases related to prior year tax positions
1,489

 
712

Decreases related to prior year tax positions

 
(181
)
Increases related to current year tax positions
2,864

 
180

Reduction due to lapse of applicable statute of limitations
(986
)
 
(169
)
Balance at December 31
$
16,545

 
$
13,178



The entire amount of unrecognized tax benefits, if recognized, would affect the Company’s effective tax rate.

The Company classifies interest expense and penalties related to the underpayment of income taxes in the consolidated financial statements as income tax expense. Consistent with the treatment of interest expense, the Company accrues interest income on overpayments of income taxes where applicable and classifies interest income as a reduction of income tax expense in the consolidated financial statements. As of December 31, 2013 and 2012, accrued interest and penalties related to unrecognized tax benefits totaled approximately $5,805 and $4,043, respectively.

It is reasonably possible that the total amount of unrecognized tax benefits will change during the next 12 months. The Company does not expect those changes to have a significant impact on its consolidated financial statements. The expected timing of payments cannot be determined with any degree of certainty.

As of December 31, 2013, the Company is under audit by the IRS for tax years ended December 31, 2010, 2009 and 2008. All federal tax years prior to 2004 are closed by statute. The Company is subject to tax examination in various U.S. state jurisdictions for tax years 2003 to the present, as well as various foreign jurisdictions for tax years 2005 to the present.


























Deferred income taxes reflect the net tax effects of temporary differences between the carrying amount of assets and liabilities for financial reporting purposes and the amounts used for income tax purposes. Significant components of the Company's deferred tax assets and liabilities at December 31 are as follows:
 
2013
 
2012
Deferred tax assets:
 
 
 
Accrued expenses
$
56,351

 
$
43,622

Warranty accrual
25,973

 
26,296

Deferred compensation
15,776

 
18,587

Allowance for doubtful accounts
8,280

 
9,239

Inventories
13,437

 
12,930

Deferred revenue
14,900

 
15,101

Pension and post-retirement benefits
48,565

 
66,222

Finance lease receivables

 
6,210

Tax credits
34,146

 
23,738

Net operating loss carryforwards
79,300

 
74,528

Capital loss carryforwards
2,853

 
3,534

State deferred taxes
13,630

 
17,341

Other
2,233

 
5,903

 
315,444

 
323,251

Valuation allowance
(92,138
)
 
(57,303
)
Net deferred tax assets
$
223,306

 
$
265,948

 
 
 
 
Deferred tax liabilities:
 
 
 
Property, plant and equipment
$
15,989

 
$
14,369

Goodwill and intangible assets
19,978

 
41,175

Finance lease receivables
1,042

 

Investment in partnership
12,824

 
17,056

Undistributed earnings
27,766

 
5,016

Other
6,759

 
3,511

Net deferred tax liabilities
84,358

 
81,127

Net deferred tax asset
$
138,948

 
$
184,821



Deferred income taxes reported in the consolidated balance sheets as of December 31 are as follows:
 
2013
 
2012
Deferred income taxes - current assets
$
110,165

 
$
143,248

Deferred income taxes - long-term assets
39,461

 
76,375

Other current liabilities
(1,528
)
 
(552
)
Deferred income taxes - long-term liabilities
(9,150
)
 
(34,250
)
Net deferred tax asset
$
138,948

 
$
184,821



At December 31, 2013, the Company had domestic and international NOL carryforwards of $519,533, resulting in an NOL deferred tax asset of $79,300. Of these NOL carryforwards, $390,529 expires at various times between 2014 and 2034 and $129,004 does not expire. At December 31, 2013, the Company had a domestic foreign tax credit carryforward resulting in a deferred tax asset of $26,481 that will expire between 2018 and 2023 and a general business credit carry forward resulting in a deferred tax asset of $8,011 that will expire between 2029 and 2033.
 


At December 31, 2012, the Company had domestic and international NOL carryforwards of $520,803, resulting in an NOL deferred tax asset of $74,528. Of these NOL carryforwards, $407,827 expires at various times between 2013 and 2033 and $112,976 does not expire. At December 31, 2012, the Company had a domestic foreign tax credit carryforward resulting in a deferred tax asset of $24,263 that will expire between 2017 and 2020 and a general business credit carry forward resulting in a deferred tax asset of $780 that will expire between 2031 and 2032.

The Company has a valuation allowance to reflect the estimated amount of certain foreign and state deferred tax assets that, more likely than not, will not be realized. The net change in total valuation allowance for the years ended December 31, 2013 and 2012 was an increase of $34,835 and a decrease of $9,685, respectively. The 2013 increase in valuation allowance is primarily attributable to recording valuation allowances for Brazil and Italy deferred tax assets, partially offset by the release of a valuation allowance for Switzerland deferred tax assets. The 2012 reduction in valuation allowance is primarily attributable to the write off of deferred tax assets and corresponding valuation allowance for dissolved legal entities. The Company believes that net deferred tax assets are more likely than not to be realized due to income generated by future operations.

For the years ended December 31, 2013 and 2012, provisions were made for foreign withholding taxes and estimated U.S. income taxes, less available tax credits, which may be incurred upon the remittance of certain undistributed earnings in foreign subsidiaries and foreign unconsolidated affiliates. Provisions have not been made for income taxes on approximately $425,997 of undistributed earnings at December 31, 2013 in foreign subsidiaries and corporate joint ventures that are deemed permanently reinvested. Determination of the amount of unrecognized deferred income tax liabilities on these earnings is not practicable because such liability, if any, depends on certain circumstances existing if and when remittance occurs. A deferred tax liability will be recognized if and when the Company no longer plans to permanently reinvest these undistributed earnings.