Income Taxes (Tables)

12 Months Ended

Dec. 31, 2023

Income Tax Disclosure [Abstract]

Schedule of income before income tax, domestic and foreign

Domestic and foreign components of income (loss) from continuing operations before income taxes are shown below: 

	Year Ended December 31,
(in Millions)	2023		2022		2021
Domestic	$	(312.7)	$	(89.6)	$	(57.5)
Foreign	612.9		1,073.5		955.3
Total	$	300.2	$	983.9	$	897.8

Schedule of components of income tax expense (benefit)

The provision (benefit) for income taxes attributable to income (loss) from continuing operations consisted of: 

	Year Ended December 31,
(in Millions)	2023		2022		2021
Current:
Federal	$	58.5	$	45.7	$	(15.1)
Foreign	113.9		152.1		96.6
State	1.1		0.1		0.4
Total current	$	173.5	$	197.9	$	81.9
Deferred:
Federal	$	(82.7)	$	(28.6)	$	18.4
Foreign	(1,212.0)		(27.4)		(7.1)
State	1.9		3.3		(0.7)
Total deferred	$	(1,292.8)	$	(52.7)	$	10.6
Total	$	(1,119.3)	$	145.2	$	92.5

Schedule of effective income tax rate reconciliation

The effective income tax rate applicable to income from continuing operations before income taxes was different from the statutory U.S. federal income tax rate due to the factors listed in the following table: 

	Year Ended December 31,
(in Millions)	2023		2022		2021
U.S. Federal statutory rate	$	63.0	$	206.6	$	188.6
Foreign earnings subject to different tax rates (1)	(130.7)		(152.7)		(182.4)
State and local income taxes, less federal income tax benefit	2.5		5.5		7.6
Research and development and miscellaneous tax credits(2)	(1,154.6)		(5.7)		(8.6)
Tax on dividends, deemed dividends, and GILTI (3)	37.0		24.6		44.5
Changes to unrecognized tax benefits	10.5		10.5		(28.7)
Nondeductible expenses	9.3		19.6		11.5
Change in valuation allowance (4)	172.5		71.3		84.7
Exchange gains and losses (5)	(18.4)		(12.0)		(8.6)
Other (6)	(110.4)		(22.5)		(16.1)
Total Tax Provision	$	(1,119.3)	$	145.2	$	92.5

____________________ 

(1)A significant amount of our earnings is generated by our foreign subsidiaries (e.g., Singapore, Hong Kong, and Switzerland), which tax earnings at lower statutory rates than the United States federal statutory rate. Our future effective tax rates may be materially impacted by a future change in the composition of earnings from foreign and domestic tax jurisdictions.

(2)The year ended December 31, 2023 is primarily related to ten-year nonrefundable tax credits granted to the Company's Swiss subsidiaries, as discussed further below.

(3)The years ended December 31, 2023, 2022, and 2021 includes tax expense of $25.5 million, $17.8 million, and $36.2 million, respectively, associated with the global intangible low-taxed income (GILTI) provisions.

(4)The year ended December 31, 2023 is primarily related to the estimated portion of nonrefundable tax credits within our Swiss operations that are not expected to be utilized and net operating losses and other deferred tax assets within our Argentina operations, partially offset by the release of the valuation allowance within our Brazil operations, as described further below. The year ended December 31, 2022 is primarily related to net operating losses and other deferred tax assets within our Brazil and Argentina operations. The year ended December 31, 2021 is primarily related to net operating losses and other deferred tax assets within our Brazil and Luxembourg operations.

(5)Includes the impact of transaction gains or losses on net monetary assets for which no corresponding tax expense or benefit is realized and the tax provision for statutory taxable gains or losses in foreign jurisdictions for which there is no corresponding amount in income before taxes.

(6)The year ended December 31, 2023 includes a net decrease of approximately $120 million related to adjustments of deferred tax balances in Singapore, Puerto Rico, and Switzerland. The year ended December 31, 2022 included a $39.7 million decrease related to certain deferred tax liabilities as a result of the extension of our incentive tax rate in Puerto Rico. The year ended December 31, 2021 included a $37.1 million decrease related to deferred tax liabilities associated with intercompany investments in foreign subsidiaries.

Schedule of deferred tax assets and liabilities

Significant components of our deferred tax assets and liabilities were attributable to:

	December 31,
(in Millions)	2023		2022
Reserves for discontinued operations, environmental and restructuring	$	144.7	$	121.4
Accrued pension and other postretirement benefits	9.8		9.6
Capital loss, foreign tax and other credit carryforwards	1,136.0		3.5
Net operating loss carryforwards	411.2		315.2
Deferred expenditures capitalized for tax	94.5		71.3
Other accruals and reserves	234.0		219.3
Deferred tax assets	$	2,030.2	$	740.3
Valuation allowance, net	(588.4)		(457.6)
Deferred tax assets, net of valuation allowance	$	1,441.8	$	282.7
Intangibles, Property, plant and equipment, and Investments, net	263.3		393.5
Deferred tax liabilities	$	263.3	$	393.5
Net deferred tax assets (liabilities)	$	1,178.5	$	(110.8)

Summary of income tax contingencies

A reconciliation of the beginning and ending amount of unrecognized tax benefits is as follows: 

	December 31,
(in Millions)	2023		2022		2021
Balance at beginning of year	$	46.1	$	41.9	$	76.2
Increases related to positions taken in the current year	2.4		4.8		2.4
Increases and decreases related to positions taken in prior years	3.5		2.9		(26.4)
Decreases related to lapse of statutes of limitations	(0.8)		(3.5)		(10.3)
Settlements during the current year	—		—		—
Decreases for tax positions on dispositions	—		—		—
Balance at end of year (1)	$	51.2	$	46.1	$	41.9

____________________ 

(1)At December 31, 2023, 2022, and 2021 we recognized an offsetting non-current asset of $12.9 million, $12.8 million, and $14.4 million respectively, relating to the indirect income tax benefits associated with specific uncertain tax positions presented above.