Income Taxes

6 Months Ended

Jun. 30, 2020

Income Tax Disclosure [Abstract]

Income Taxes

INCOME TAXES

Uncertain Tax Positions

As of June 30, 2020, the Company had $80.2 million of unrecognized tax benefits recorded in Other liabilities and $0.7 million recorded to Other current liabilities. If these unrecognized tax benefits were recognized, the effective tax rate would be affected.

As of June 30, 2020, the Company had accrued interest and penalties of $14.7 million classified in Other liabilities and less than $0.1 million classified in Other current liabilities.

As of June 30, 2020, the Company’s aggregate provisions for uncertain tax positions, including interest and penalties, was $95.6 million associated with tax positions asserted in various jurisdictions, none of which is individually material.

The Company regularly repatriates earnings from non-U.S. subsidiaries. As the Company repatriates these funds to the U.S., they will be required to pay income taxes in certain U.S. states and applicable foreign withholding taxes during the period when such repatriation occurs. Accordingly, as of June 30, 2020, the Company had a deferred tax liability of $42.8 million for the effect of repatriating the funds to the U.S., attributable to various non-U.S. subsidiaries. There is no deferred tax liability associated with non-U.S. subsidiaries where we intend to indefinitely reinvest the earnings to fund local operations and/or capital projects.

The Company has ongoing income tax audits and legal proceedings which are at various stages of administrative or judicial review. In addition, the Company has open tax years with various taxing jurisdictions that range primarily from 2010 to 2019. Based on currently available information, the Company does not believe the outcome of any of these tax audits and other tax positions related to open tax years, when finalized, will have a material impact on its results of operations.

The Company also has other ongoing tax audits and legal proceedings that relate to indirect taxes, such as value-added taxes, sales and use taxes and property taxes, which are discussed in Note 15.

Effective Tax Rate

The effective tax rate for the three months ended June 30, 2020 was 15.2% compared with 18.1% for the three months ended June 30, 2019. The quarter-over-quarter decrease is primarily due to lower repatriation costs, a favorable mix of earnings and non-U.S. provision to return adjustments recorded in 2020, partially offset by an increase in loss provisions.

The effective tax rate for the six months ended June 30, 2020 was 16.4% compared with 17.8% for the six months ended June 30, 2019. The year-over-year decrease is primarily due to lower repatriation costs and non-U.S. provision to return adjustments recorded in 2020, partially offset by an unfavorable mix of earnings and an increase in loss provisions.