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Income Taxes
3 Months Ended
Jun. 30, 2020
Income Tax Disclosure [Abstract]  
Income Taxes Income Taxes
 
The Company's effective tax rate was 4.5% for the six months ended June 30, 2020 as compared to 24.5% for the six months ended June 30, 2019. The effective tax rate of 4.5% for the six months ended June 30, 2020 (the tax benefit of $5.3 million on the pretax book loss of $117.7 million) was significantly different than the rate of the prior comparable period and the statutory federal tax rate of 21% because the $92.2 million impairment of goodwill is not deductible for federal income tax purposes and therefore has no associated tax benefit. The Company did recognize a deferred tax benefit of $3.4 million as a discrete item related to the $14.3 million impairment of Applebee's tradename and reacquired franchise rights in the second quarter of 2020.

The total gross unrecognized tax benefit as of June 30, 2020 and December 31, 2019 was $7.9 million and $7.6 million, respectively, excluding interest, penalties and related tax benefits. The Company estimates the unrecognized tax benefit as of June 30, 2020 may decrease over the upcoming 12 months by an amount up to $1.5 million related to settlements with taxing authorities, statutes of limitations expirations and method changes. For the remaining liability, due to the uncertainties related to these tax matters, the Company is unable to make a reasonable estimate as to when cash settlement with a taxing authority will occur. 

As of June 30, 2020, accrued interest was $2.9 million and accrued penalties were less than $0.1 million, excluding any related income tax benefits. As of December 31, 2019, accrued interest was $2.5 million and accrued penalties were less than $0.1 million, excluding any related income tax benefits. The Company recognizes interest accrued related to unrecognized tax benefits and penalties as a component of its income tax provision recognized in its Consolidated Statements of Comprehensive (Loss) Income.
The Company files federal income tax returns and the Company or one of its subsidiaries file income tax returns in various state and international jurisdictions. With few exceptions, the Company is no longer subject to federal tax examinations by tax authorities for years before 2014 and state or non-United States tax examinations by tax authorities for years before 2011. The Company believes that adequate reserves have been provided related to all matters contained in the tax periods open to examination.On March 27, 2020, the Coronavirus Aid, Relief, and Economic Security Act (“CARES Act”) was enacted in response to the COVID-19 pandemic. The Company is continuing to evaluate the impact of the CARES Act, but at present does not expect the CARES Act would result in a material impact to our income tax benefit or provision.