INCOME TAXES

12 Months Ended

Dec. 31, 2021

Income Tax Disclosure [Abstract]

INCOME TAXES

INCOME TAXES

The components of income (loss) before income taxes were as follows:

	Year Ended December 31,
(in millions)	2021		2020		2019
United States	$	51	$	(91)	$	(115)
Foreign	494		41		453
Total income (loss) before income taxes	$	545	$	(50)	$	338

The components of the provision (benefit) for income taxes from operations were as follows:

	Year Ended December 31,
(in millions)	2021		2020		2019
Current:
U.S. federal	$	1	$	(5)	$	(11)
U.S. state	4		1		2
Foreign	154		89		131
Total	$	159	$	85	$	122
Deferred:
U.S. federal	$	10	$	4	$	(3)
U.S. state	2		(1)		1
Foreign	(37)		(65)		(38)
Total	$	(25)	$	(62)	$	(40)
Total provision for income taxes	$	134	$	23	$	82

The reconciliation of the U.S. federal statutory tax rate to the effective rate were as follows:

	Year Ended December 31,
	2021		2020		2019
Statutory U.S. federal income tax rate	21.0	%	21.0	%	21.0	%
Effect of:
State income taxes, net of federal benefit	0.8		1.1		0.7
Federal benefit of R&D and foreign tax credits	(0.9)		18.9		(2.0)
US other permanent differences	0.4		(6.1)		0.8
Tax effect of international operations	0.3		10.0		0.9
Global Intangible Low Taxed Income (GILTI)	2.4		(13.0)		3.8
Foreign Derived Intangible Income (FDII)	(1.3)		11.8		(0.1)
Net effect of tax audit activity	1.6		(8.2)		0.4
Tax effect of enacted statutory rate changes on Non-U.S. jurisdictions	1.9		(0.2)		0.1
Federal tax on unremitted earnings of certain foreign subsidiaries	(0.2)		(5.4)		0.1
Valuation allowance adjustments	(1.7)		(15.3)		(1.4)
Tax effect of impairment of goodwill and intangibles	—		(60.8)		(0.1)
Other	0.3		0.2		0.1
Effective income tax rate on operations	24.6	%	(46.0	%)	24.3	%

The tax effect of significant temporary differences giving rise to deferred tax assets and liabilities were as follows:

	Year Ended December 31,
	2021				2020
(in millions)	Deferred Tax Asset		Deferred Tax Liability		Deferred Tax Asset		Deferred Tax Liability
Commission and bonus accrual	$	6	$	—	$	8	$	—
Employee benefit accruals	51		—		58		—
Inventory	16		—		25		—
Identifiable intangible assets	—		569		—		613
Insurance premium accruals	3		—		3		—
Miscellaneous accruals	27		—		24		—
Other	17		—		10		—
Unrealized losses included in AOCI	47		—		98		—
Property, plant and equipment	—		47		—		50
Lease right-of-use asset	—		47		—		42
Lease right-of-use liability	47		—		42		—
Product warranty accruals	1		—		1		—
Foreign tax credit and R&D carryforward	49		—		60		—
Restructuring and other cost accruals	5		—		9		—
Sales and marketing accrual	14		—		7		—
Taxes on unremitted earnings of foreign subsidiaries	—		5		—		6
Tax loss carryforwards and other tax attributes	275		—		280		—
Subtotal	$	558	$	668	$	625	$	711
Valuation allowances	(267)		—		(287)		—
Total	$	291	$	668	$	338	$	711

Deferred tax assets and liabilities are included in the following Consolidated Balance Sheets line items at December 31 were as follows:

(in millions)	2021		2020
Assets
Other noncurrent assets	$	14	$	8
Liabilities
Deferred income taxes	$	391	$	381

The Company has $45 million of foreign tax credit carryforwards at December 31, 2021, of which $36 million will expire in 2025, $3 million will expire in 2027, and $6 million will expire at various times from 2028 through 2031.

The Company has tax loss carryforwards related to certain foreign and domestic subsidiaries of approximately $1,278 million at December 31, 2021, of which $1,017 million expires at various times through 2041 and $261 million may be carried forward indefinitely. Included in deferred income tax assets at December 31, 2021 are tax benefits totaling $228 million, before valuation allowances, for the tax loss carryforwards. In addition, the Company has recorded a deferred tax asset of $48 million, related to tax attributes.

The Company has recorded $210 million of valuation allowance to offset the tax benefit of net operating losses, $45 million to offset the tax benefit of foreign tax credits, and $12 million of valuation allowance for other deferred tax assets. The Company has recorded these valuation allowances due to the uncertainty that these assets can be realized in the future.

The Company has provided $5 million of withholding taxes on certain undistributed earnings of its foreign subsidiaries that the Company anticipates will be repatriated.

Tax Contingencies

The total amount of gross unrecognized tax benefits at December 31, 2021 is approximately $42 million, of this total, approximately $41 million represents the amount of unrecognized tax benefits that, if recognized, would affect the effective income tax rate. It is reasonably possible that certain amounts of unrecognized tax benefits will significantly increase or decrease within twelve months of the reporting date of the Company’s consolidated financial statements. Expiration of statutes of limitation in various jurisdictions during the next twelve months could include unrecognized tax benefits of approximately $1 million. Of this approximately $1 million represents the amount of unrecognized tax benefits that, if recognized, would affect the effective income tax rate.

The total amount of accrued interest and penalties were $8 million and $4 million at December 31, 2021 and 2020, respectively. The Company has consistently classified interest and penalties recognized in its consolidated financial statements as income taxes based on the accounting policy election of the Company. During the years ended December 31, 2021 and 2020, the Company recognized income tax expense of $2 million each year, related to interest and penalties. During the year ended December 31, 2019, the Company recognized income tax benefit of $2 million, related to interest and penalties.

The Company is subject to U.S. federal income tax as well as income tax of multiple state and foreign jurisdictions. The significant jurisdictions include the U.S., Germany, Sweden and Switzerland. The Company has substantially concluded all U.S. federal income tax matters for years through 2011. The Company is currently under audit for the tax years 2012, 2013, 2015 and 2016. For further information on the Internal Revenue Service (“IRS”) Audit, see Note 22, Commitments and Contingencies. The tax years 2014 through 2020 are subject to future potential tax audit adjustments. The Company has concluded audits in Germany through the tax year 2013 and is currently under audit for the years 2014 through 2017. The tax years 2018 through 2020 are subject to future potential audit adjustments in Germany. The taxable years that remain open for Sweden are 2013 through 2020. For information related to Sweden, see Note 22, Commitments and Contingencies. The taxable years that remain open for Switzerland are 2011 through 2020.

The activity recorded for unrecognized tax benefits were as follows:

(in millions)	2021		2020		2019
Unrecognized tax benefits at beginning of period	$	27	$	24	$	28
Gross change for prior-period positions	6		1		—
Gross change for current year positions	2		1		—
Decrease due to settlements and payments	—		—		(4)
Decrease due to statute expirations	—		—		—
Increase due to effect of foreign currency translation	—		1		—
Decrease due to effect from foreign currency translation	(1)		—		—
Unrecognized tax benefits at end of period	$	34	$	27	$	24

U.S. Federal Legislative Changes

Undistributed earnings of foreign subsidiaries and related companies that are deemed to be permanently invested amounted to $1,771 million at December 31, 2021 and $1,807 million at December 31, 2020. The Tax Cuts and Jobs Act (the “act” or “U.S. tax reform”) imposed U.S. tax on all post-1986 foreign unrepatriated earnings accumulated through December 31, 2017. Unrepatriated earnings generated after December 31, 2017, are now subject to tax in the current year. All undistributed earnings are still subject to certain taxes upon repatriation, primarily where foreign withholding taxes apply. It is not practicable to calculate the unrecognized deferred tax liability on undistributed earnings.

For the Global Intangible Low Taxed Income (GILTI) provision of the Act, the Company has made the policy election to record any liability associated with GILTI in the period in which it is incurred.

In March 2020, in response to the impact of the COVID-19 pandemic in the U.S. and across the globe, the U.S. Congress passed the Coronavirus Aid, Relief and Economic Security (CARES) Act. In December 2020, the U.S. Congress passed a second relief package, Consolidated Appropriations Act, 2021. The enactment period impacts to the Company were immaterial to income tax expense.