Income Taxes (Tables)

12 Months Ended

Dec. 29, 2013

Schedule of Income before Income Tax, Domestic and Foreign [Table Text Block]

Income (loss) from continuing operations before income taxes and noncontrolling interests is set forth below:



	Year Ended
	2013		2012			2011
Domestic	$	49,635	$	(23,154	)	$	11,967
Foreign	9,417		10,029			12,473
	$	59,052	$	(13,125	)	$	24,440

Schedule of Components of Income Tax Expense (Benefit) [Table Text Block]

The (provision for) benefit from income taxes from continuing operations is set forth below:



	Year Ended
	2013			2012			2011
Current:
U.S. Federal	$	(1,603	)	$	104		$	—
State	7,879			(669		)	(675		)
Foreign	(7,446		)	(8,667		)	(5,540		)
Current tax provision	(1,170		)	(9,232		)	(6,215		)
Deferred:
U.S. Federal	(21,103		)	6,458			1,367
State	6,173			18,026			(2,788		)
Foreign	1,946			5,831			1,108
Deferred tax (provision) benefit	(12,984		)	30,315			(313		)
Income tax (provision) benefit	$	(14,154	)	$	21,083		$	(6,528	)

Schedule of Deferred Tax Assets and Liabilities [Table Text Block]

Deferred tax assets (liabilities) are set forth below:



	Year End
	2013			2012
Deferred tax assets:
Tax credit carryforwards	$	102,783		$	91,319
Accrued compensation and related benefits	40,289			35,397
Accrued expenses and reserves	31,555			32,090
Unfavorable leases	13,913			16,581
Net operating loss carryforwards	13,127			108,297
Deferred rent	13,121			11,215
Other	8,682			7,227
Valuation allowances	(10,548		)	(21,052		)
Total deferred tax assets	212,922			281,074
Deferred tax liabilities:
Intangible assets	(473,011		)	(480,790		)
Owned and leased fixed assets net of related obligations	(83,352		)	(121,706		)
Other	(18,996		)	(25,306		)
Total deferred tax liabilities	(575,359		)	(627,802		)
	$	(362,437	)	$	(346,728	)

Summary of Net Operating Loss and Tax Credit Carryforwards [Table Text Block]

The amounts and expiration dates of net operating loss and tax credit carryforwards are as follows:



	Amount		Expiration
Tax credit carryforwards:
U.S. federal credits (primarily foreign tax credits and jobs credits)	$	101,208	2015-2033
Foreign tax credits of non-U.S. subsidiaries	1,575		2021-2022
Total	$	102,783

Net operating loss carryforwards:
U.S federal net operating loss carryforwards	$	77,153	2031-2032
State net operating loss carryforwards	986,684		2014-2032
Total	$	1,063,837

Schedule of Effective Income Tax Rate Reconciliation [Table Text Block]

The reconciliation of income tax computed at the U.S. Federal statutory rate to reported income tax is set forth below:



	Year Ended
	2013			2012			2011
Income tax (provision) benefit at the U.S. Federal statutory rate	$	(20,668	)	$	4,594		$	(8,554	)
State income tax (provision) benefit, net of U.S. Federal income tax effect	(1,370		)	11,364			(2,848		)
Valuation allowances (a)	10,504			(3,655		)	597
Jobs tax credits, net	4,384			970			1,914
Foreign and U.S. tax effects of foreign operations (b)	2,886			347			1,147
Dividends received deduction (c)	1,424			1,133			—
Corrections related to prior years’ tax matters (d)	—			7,620			—
Non-deductible goodwill (e)	(9,875		)	—			—
Non-deductible expenses and other, net	(1,439		)	(1,290		)	1,216
	$	(14,154	)	$	21,083		$	(6,528	)

_______________


(a)	Includes changes for deferred tax assets generated or utilized during the current year and changes in our judgment regarding the likelihood of the utilization of deferred tax assets, primarily state net operating loss carryforwards that existed at the beginning of the year.


(b)	2013 includes reversal of deferred taxes on investments in foreign subsidiaries now considered permanently invested outside of the U.S.


(c)	We received dividends of $40,145 and $4,625 during 2013 and 2012, respectively, from our investment in Arby’s. See Note 6 for further information.


(d)	Corrections in 2012 related to tax matters in prior years for the effects of tax depreciation in states that do not follow federal law of $3,300, the effects of a one-time federal employment tax credit in 2011 of $2,220 and a correction to certain deferred tax assets and liabilities of $2,100. See Note 26 for further information.


(e)	Substantially all of the goodwill included in the gain on sales of restaurants, as noted below, and the impairment of international goodwill was non-deductible for tax purposes. See Notes 2 and 8 for further information.

Schedule of Unrecognized Tax Benefits Roll Forward [Table Text Block]

As of December 29, 2013, the Company had unrecognized tax benefits of $23,897, which, if resolved favorably would reduce income tax expense by $17,664. A reconciliation of the beginning and ending amount of unrecognized tax benefits follows:



	Year End
	2013			2012			2011
Beginning balance	$	28,848		$	30,614		$	36,434
Additions:
Tax positions of prior years	3,579			3,410			948
Reductions:
Tax positions of prior years	(4,914		)	(2,964		)	(3,410		)
Settlements	(2,416		)	(1,327		)	(1,922		)
Lapse of statute of limitations	(1,200		)	(885		)	(1,436		)
Ending balance	$	23,897		$	28,848		$	30,614