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Income Taxes
12 Months Ended
Dec. 31, 2020
Income Tax Disclosure [Abstract]  
Income Taxes

Note 8 — Income Taxes

Income before income taxes and the provision for income taxes, for the three years ended December 31, 2020, were as follows:

 

(In millions)

 

2020

 

 

2019

 

 

2018

 

Income before income taxes:

 

 

 

 

 

 

 

 

 

 

 

 

U.S.

 

$

0.8

 

 

$

284.1

 

 

$

222.9

 

International

 

 

(28.5

)

 

 

95.6

 

 

 

110.6

 

Total (loss) income before income taxes

 

$

(27.7

)

 

$

379.7

 

 

$

333.5

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Income tax (benefit) expense:

 

 

 

 

 

 

 

 

 

 

 

 

Current:

 

 

 

 

 

 

 

 

 

 

 

 

U.S.

 

$

(11.3

)

 

$

49.1

 

 

$

18.3

 

International

 

 

1.7

 

 

 

11.8

 

 

 

14.9

 

Current income tax (benefit) expense

 

 

(9.6

)

 

 

60.9

 

 

 

33.2

 

Deferred:

 

 

 

 

 

 

 

 

 

 

 

 

U.S.

 

 

0.1

 

 

 

3.8

 

 

 

26.8

 

International

 

 

(51.5

)

 

 

12.1

 

 

 

2.5

 

Deferred income tax (benefit) expense

 

 

(51.4

)

 

 

15.9

 

 

 

29.3

 

Total income tax (benefit) expense

 

$

(61.0

)

 

$

76.8

 

 

$

62.5

 

 

 

A reconciliation of the provision for income taxes at the U.S. federal statutory income tax rate of 21.0% to the effective income tax rate, for the year ended December 31, 2020 and 2019, 2018 is as follows:

 

(In millions)

 

2020

 

 

2019

 

 

2018

 

(Benefit) provision for taxes at U.S. federal statutory rate

 

$

(5.8

)

 

$

79.7

 

 

$

70.0

 

State and local taxes, net of federal benefit

 

 

(4.2

)

 

 

3.6

 

 

 

7.2

 

Foreign effective rate differential

 

 

(1.9

)

 

 

5.1

 

 

 

4.6

 

Tax credits

 

 

(3.0

)

 

 

(8.8

)

 

 

(7.8

)

Change in valuation allowance

 

 

(39.5

)

 

 

(1.9

)

 

 

(3.4

)

Remeasurement of deferred taxes

 

 

3.5

 

 

 

0.4

 

 

 

(9.0

)

Transition tax on undistributed foreign earnings

 

 

 

 

 

 

 

 

1.6

 

Excess tax benefits on stock-based compensation

 

 

(0.9

)

 

 

(4.9

)

 

 

(4.6

)

Other

 

 

(4.3

)

 

 

1.0

 

 

 

(0.5

)

(Decrease) increase in reserves for uncertain tax positions

 

 

(4.9

)

 

 

1.2

 

 

 

(1.3

)

Global intangible low taxed income

 

 

 

 

 

1.4

 

 

 

5.7

 

Total income tax (benefit) expense

 

$

(61.0

)

 

$

76.8

 

 

$

62.5

 

   

We do not provide for additional income or withholding taxes for any undistributed foreign earnings as we do not currently have any specific plans to repatriate funds from our international subsidiaries; however, we may do so in the future if a dividend can be remitted with no material tax impact. As of December 31, 2020, we have approximately $720.2 million of unremitted foreign earnings that we intend to keep indefinitely reinvested. Additionally, due to withholding tax, basis computations and other tax related considerations, it is not practicable to estimate any taxes to be provided on outside basis differences at this time.   

Deferred Income Taxes

Deferred income taxes result from tax attributes including foreign tax credits, net operating loss carryforwards and temporary differences between the recognition of items for income tax purposes and financial reporting purposes. Principal components of deferred income taxes as of December 31, 2020 and 2019 are: 

 

(In millions)

 

2020

 

 

2019

 

Assets

 

 

 

 

 

 

 

 

Net operating loss carryforwards

 

$

96.5

 

 

$

71.6

 

Capital loss carryforward

 

 

1.6

 

 

 

1.7

 

ASC 606 - revenue from contracts with customers

 

 

8.4

 

 

 

9.9

 

Tax credit carryforwards

 

 

9.9

 

 

 

8.6

 

Stock-based compensation

 

 

7.6

 

 

 

7.7

 

Other comprehensive income

 

 

6.1

 

 

 

6.3

 

Inventory reserves

 

 

9.6

 

 

 

11.8

 

Reserves and other

 

 

5.2

 

 

 

1.5

 

Subtotal

 

 

144.9

 

 

 

119.1

 

Valuation allowance

 

 

(6.9

)

 

 

(44.7

)

Total assets

 

$

138.0

 

 

$

74.4

 

Liabilities

 

 

 

 

 

 

 

 

Accelerated depreciation

 

 

(194.5

)

 

 

(189.1

)

Accelerated amortization

 

 

(14.8

)

 

 

(13.2

)

Other

 

 

(8.8

)

 

 

(6.0

)

Total liabilities

 

$

(218.1

)

 

$

(208.3

)

Net deferred tax liabilities

 

$

(80.1

)

 

$

(133.9

)

 

 

Deferred tax assets and deferred tax liabilities as presented in the consolidated balance sheets as of December 31, 2020 and 2019 are as follows and are recorded in other assets and deferred income taxes in the consolidated balance sheets:

 

(In millions)

 

2020

 

 

2019

 

Long-term deferred tax assets, net

 

$

72.9

 

 

$

21.8

 

Long-term deferred tax liability, net

 

 

(153.0

)

 

 

(155.7

)

Net deferred tax liabilities

 

$

(80.1

)

 

$

(133.9

)

 

The deferred tax assets for the respective periods were assessed for recoverability and, where applicable, a valuation allowance was recorded to reduce the total deferred tax asset to an amount that will, more likely than not, be realized in the future. The valuation allowance as of December 31, 2020 relates primarily to certain US tax attributes for which we have determined, based upon historical results and projected future book and taxable income levels, that a valuation allowance should continue to be maintained. The valuation allowance decreased by $37.8 million in the current year primarily due to a legal entity rationalization and treasury realignment initiative in the third quarter. The valuation allowance as of December 31, 2019 relates primarily to net operating loss carryforwards of our foreign subsidiaries for which we have determined, based upon historical results, and projected future book and taxable income levels, that a valuation allowance should continue to be maintained. The net change in the total valuation allowance for the years ended December 31, 2020 and 2019, was a decrease of $37.8 million and $4.1 million, respectively.     

Although realization is not assured, we have concluded that it is more-likely-than-not that the deferred tax assets, for which a valuation allowance was determined to be unnecessary, will be realized in the ordinary course of operations based on the available positive and negative evidence, including scheduling of deferred tax liabilities and projected income from operating activities. The amount of the net deferred tax assets considered realizable, however, could be reduced in the near term if actual future income or income tax rates are lower than estimated, or if there are differences in the timing or amount of future reversals of existing taxable or deductible temporary differences.

Net Operating Loss & Tax Credit Carryforwards

At December 31, 2020, we had tax credit carryforwards for U.S. and foreign tax purposes of $9.9 million available to offset future income taxes. These credits will begin to expire if not utilized in 2021. We also had net operating loss carryforwards for U.S. state and foreign income tax purposes of $6.7 million and $380.2 million, respectively, for which there were foreign valuation allowances of $0.5 million as of December 31, 2020. Our foreign net operating losses can be carried forward without limitation in Belgium, France, Luxembourg, and the U.K. We have a partial valuation allowance against certain foreign net operating losses for which the Company believes it is not more likely than not that the net operating losses will be utilized.

Uncertain Tax Positions

Our unrecognized tax benefits at December 31, 2020, relate to various foreign and U.S. jurisdictions. The following table summarizes the activity related to our unrecognized tax benefits.

 

 

 

Unrecognized Tax Benefits

 

(In millions)

 

2020

 

 

2019

 

 

2018

 

Balance as of January 1,

 

$

18.1

 

 

$

7.5

 

 

$

12.3

 

Additions based on tax positions related to the current year

 

 

0.3

 

 

 

11.0

 

 

 

1.1

 

(Reductions) additions for tax positions of prior years

 

 

(7.9

)

 

 

(0.1

)

 

 

(5.7

)

Expiration of the statute of limitations for the assessment of taxes

 

 

 

 

 

(0.3

)

 

 

(0.3

)

Other, including currency translation

 

 

 

 

 

 

 

 

0.1

 

Balance as of December 31,

 

$

10.5

 

 

$

18.1

 

 

$

7.5

 

 

We had unrecognized tax benefits of $10.5 million at December 31, 2020, of which $2.4 million, if recognized, would impact our annual effective tax rate. In addition, we recognize interest accrued related to unrecognized tax benefits as a component of interest expense and penalties as a component of income tax expense in the consolidated statements of operations. The Company did not recognize any interest expense or penalties related to the above unrecognized tax benefits in 2020 and 2019. During 2020 we reversed $0.2 million of accrued interest related to unrecognized tax benefits. The Company had no accrued interest as of December 31, 2020 and approximately $0.2 million as of December 31, 2019.                       

We are subject to taxation in the U.S. and various states and foreign jurisdictions. The U.S. Federal tax returns have been audited through 2016. Foreign and U.S. state jurisdictions have statutes of limitations generally ranging from 3 to 5 years. Years in major jurisdictions that remain open to examination are the U.S. (2017 onward for Federal purposes and 2015 onward for state purposes), Austria (2016 onward), Belgium (2014 onward), France (2018 onward), Spain (2013 onward) and the U.K. (2017 onward). We are currently under examination in the U.S. and certain foreign tax jurisdictions.

As of December 31, 2020, we had uncertain tax positions for which it is reasonably possible that amounts of unrecognized tax benefits could significantly change over the next year. These uncertain tax positions relate to our tax returns from 2012 onward, some of which are currently under examination by certain U.S. and European tax authorities. We believe it is reasonably possible that the total amount of unrecognized tax benefits disclosed as of December 31, 2020 may decrease by approximately $1.0 million in the fiscal year ending December 31, 2021. Such possible decrease primarily relates to the expiration of statutes of limitation.