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Income Taxes
3 Months Ended
Mar. 31, 2014
Income Tax Disclosure [Abstract]  
Income Taxes
Income Taxes

For interim income tax reporting we estimate our annual effective tax rate and apply it to our year-to-date ordinary income. Tax jurisdictions with a projected or year-to-date loss for which a tax benefit cannot be realized are excluded from the annualized effective tax rate. The tax effects of unusual or infrequently occurring items, including changes in judgment about valuation allowances and effects of changes in tax laws or rates, are reported in the interim period in which they occur.

Our effective income tax rate was 34.7% and 37.6% for the three months ended March 31, 2014 and 2013. The decrease in the effective income tax rate is primarily related to the acquisition of the international operations, which resulted in income in jurisdictions with lower taxing rates and other permanent differences.

We had gross unrecognized tax benefits of $129 million and $130 million at March 31, 2014 and December 31, 2013. The amounts of net unrecognized tax benefits that, if recognized, would impact the effective tax rate are $105 million and $104 million at March 31, 2014 and December 31, 2013.

Periodically we make deposits to taxing jurisdictions which reduce the unrecognized tax benefit balance. The amount of deposits that reduced our unrecognized tax benefits in the condensed consolidated balance sheet was $46 million and $44 million at March 31, 2014 and December 31, 2013.

At March 31, 2014, we believe that it is reasonably possible that the gross unrecognized tax benefits could decrease between $48 million to $62 million in the next twelve months due to settlements or the expiration of statutes of limitations.

We recognize accrued interest and penalties associated with uncertain tax positions as a component of the income tax provision. As of March 31, 2014, accrued interest and penalties associated with uncertain tax positions were $139 million and $17 million. As of December 31, 2013, accrued interest and penalties associated with uncertain tax positions were $131 million and $18 million.

Income tax returns are filed in multiple jurisdictions and are subject to examination by taxing authorities throughout the world. We have open tax years from 2007 to 2013 with various tax jurisdictions. These open years contain matters that could be subject to differing interpretations of applicable tax laws and regulations as they relate to the amount, character, timing or inclusion of revenue and/or recognition of expenses, or the sustainability of income tax credits. Some of our state and foreign tax returns are currently under examination in various jurisdictions.

Since October 1, 2010, we have been included in GM's consolidated U.S. federal income tax returns. For taxable income we recognize in any period beginning on or after October 1, 2010, we are obligated to pay GM for our share of the consolidated U.S. federal and certain state tax liabilities. Amounts owed to GM for income taxes are accrued and recorded as a related party payable. Under our tax sharing arrangement with GM for our U.S. operations, payments for the tax years 2010 through 2014 are deferred for four years from their original due date. Any difference between the amounts paid under our tax sharing arrangement with GM and our separate return basis used for financial reporting purposes is reported in our consolidated financial statements as additional paid-in capital.