Income Taxes

Earnings before taxes for the years 2015, 2014 and 2013 were taxed under the following jurisdictions:



	2015		2014		2013
	(In millions of dollars)
Domestic	$	28.9	$	5.9	$	35.1
Foreign	33.6		10.7		13.7
Total	$	62.5	$	16.6	$	48.8

The provision for income taxes was as follows:



	2015			2014			2013
	(In millions of dollars)
Current tax expense:
U.S. federal	$	8.3		$	5.6		$	7.3
U.S. state and local	1.4			1.4			3.5
Foreign	10.8			12.7			10.4
Total current	20.5			19.7			21.2
Deferred tax expense:
U.S. federal	(10.6		)	(22.0		)	(26.9		)
U.S. state and local	0.8			(0.4		)	(1.6		)
Foreign	(2.0		)	(4.4		)	(2.8		)
Total deferred	(11.8		)	(26.8		)	(31.3		)
Total provision	$	8.7		$	(7.1	)	$	(10.1	)

Deferred taxes are comprised of the following:



	2015			2014
	(In millions of dollars)
Depreciation and amortization	$	(14.3	)	$	(14.4	)
Employee compensation and benefit plans	70.6			70.4
Workers’ compensation	21.4			21.6
Unrealized gain on securities	(36.7		)	(23.7		)
Loss carryforwards	40.6			47.2
Credit carryforwards	113.4			103.0
Other, net	8.1			11.0
Valuation allowance	(50.9		)	(58.5		)
Net deferred tax assets	$	152.2		$	156.6

The deferred tax balance is classified in the consolidated balance sheet as:



	2015			2014
	(In millions of dollars)
Current assets, deferred tax	$	—		$	34.4
Noncurrent deferred tax asset	189.3			146.3
Current liabilities, income and other taxes	—			(0.4		)
Noncurrent liabilities, other long-term liabilities	(37.1		)	(23.7		)
	$	152.2		$	156.6

As a result of early adopting ASU 2015-17 on a prospective basis, as of the 2015 year end, we reclassified our net current deferred tax asset to a net noncurrent deferred tax asset and our net current deferred tax liability to a net noncurrent deferred tax liability.

The differences between income taxes from continuing operations for financial reporting purposes and the U.S. statutory rate of 35% are as follows:



	2015			2014			2013
	(In millions of dollars)
Income tax based on statutory rate	$	21.9		$	5.8		$	17.1
State income taxes, net of federal benefit	1.3			0.7			1.2
General business credits	(17.9		)	(17.5		)	(26.2		)
Life insurance cash surrender value	0.3			(2.2		)	(5.8		)
Foreign items	(2.3		)	(0.2		)	0.3
Foreign business taxes	3.7			4.2			3.9
Foreign tax law change	(0.7		)	(2.2		)	(4.6		)
Non-deductible expenses	2.3			2.1			1.6
Change in deferred tax realizability	—			2.2			2.8
Other, net	0.1			—			(0.4		)
Total	$	8.7		$	(7.1	)	$	(10.1	)

General business credits primarily represent U.S. work opportunity credits. In 2012, the work opportunity credit was available only for veterans and pre-2012 hires. The full credit was retroactively reinstated on January 2, 2013, resulting in the inclusion of $9.3 million of tax benefits during 2013 that would have been recognized in 2012 if the law had been in effect. Foreign items include foreign income tax rate differences, foreign tax credits and deductions, and foreign non-deductible expenses and non-taxable income. Foreign business taxes include the French business tax and other taxes based on revenue less certain expenses and are classified as income taxes under ASC Topic 740 (“ASC 740”), Income Taxes.

The Company has U.S. general business credit carryforwards of $111.6 million which will expire from 2031 to 2035, foreign tax credit carryforwards of $1.7 million that expire from 2022 to 2024 and $0.2 million of state credit carryforwards that expire from 2016 to 2035, or have no expiration. The net tax effect of state and foreign loss carryforwards at year-end 2015 totaled $40.6 million, which expire as follows (in millions of dollars):



Year	Amount
2016-2018	$	2.3
2019-2021	1.9
2022-2025	0.4
2026-2029	0.1
No expiration	35.9
Total	$	40.6

The Company has established a valuation allowance for loss carryforwards and future deductible items in certain foreign jurisdictions, and for U.S. foreign tax credit carryforwards. The valuation allowance is determined in accordance with the provisions of ASC 740, which requires an assessment of both negative and positive evidence when measuring the need for a valuation allowance. The Company’s recent losses in these foreign jurisdictions, and its recent lack of adequate U.S. foreign source income to fully utilize foreign tax credit carryforwards, represented sufficient negative evidence to require a valuation allowance under ASC 740. The Company intends to maintain a valuation allowance until sufficient positive evidence exists to support realization of the foreign deferred tax assets.

Provision has not been made for U.S. or additional foreign income taxes on an estimated $119.8 million of undistributed earnings which are permanently reinvested. If these earnings were to be repatriated, the Company would be subject to U.S. income taxes and foreign withholding taxes, adjusted for foreign tax credits. Determination of the amount of any unrecognized deferred income tax liability related to these undistributed earnings is not practicable due to the complexities associated with this hypothetical calculation.

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



	2015			2014			2013
	(In millions of dollars)
Balance at beginning of the year	$	2.4		$	2.8		$	2.9

Additions for prior years’ tax positions	0.1			—			—
Reductions for prior years’ tax positions	(0.7		)	(0.4		)	(0.1		)
Additions for settlements	—			—			—
Reductions for settlements	—			—			—
Reductions for expiration of statutes	(0.1		)	—			—

Balance at end of the year	$	1.7		$	2.4		$	2.8

If the $1.7 million in 2015, $2.4 million in 2014 and $2.8 million in 2013 of unrecognized tax benefits were recognized, they would have a favorable effect of $1.1 million in 2015, $1.5 million in 2014 and $1.8 million in 2013 on income tax expense.

The Company recognizes both interest and penalties as part of the income tax provision. The Company recognized a benefit of $0.2 million in 2015, expense of $0.1 million in 2014 and expense of $0.1 million in 2013 for interest and penalties. Accrued interest and penalties were $0.2 million at year-end 2015 and $0.4 million at year-end 2014.

The Company files income tax returns in the U.S. and in various states and foreign countries. The tax periods open to examination by the major taxing jurisdictions to which the Company is subject include the U.S. for fiscal years 2012 through 2015, Australia for fiscal years 2011 through 2015, Canada for fiscal years 2008 through 2015, France for fiscal years 2013 through 2015, Mexico for fiscal years 2010 through 2015, Portugal for fiscal years 2012 through 2015, Singapore for fiscal years 2011 through 2015, Switzerland for fiscal years 2006 through 2015, and United Kingdom for fiscal years 2012 through 2015.

The Company and its subsidiaries have various income tax returns in the process of examination. The unrecognized tax benefit and related interest and penalty balances include approximately $0.5 million for 2015, related to tax positions which are reasonably possible to change within the next twelve months due to income tax audits, settlements and statute expirations.