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Income Taxes (Tables)

12 Months Ended

Sep. 27, 2013

Significant components of the income tax provision

Significant components of the income tax provision for 2013, 2012 and 2011 are as follows ($ in millions):



	For the Years Ended
	September 27, 2013			September 28, 2012			September 30, 2011
Current:
United States:
Federal	$	14		$	(4	)	$	(4	)
State	8			6			(2		)
Non U.S.	81			147			125
Current income tax provision	$	103		$	149		$	119
Deferred:
United States:
Federal	$	(12	)	$	(10	)	$	(17	)
State	5			(2		)	(12		)
Non U.S.	12			183			22
Deferred income tax provision	5			171			(7		)
	$	108		$	320		$	112

Reconciliation between U.S. federal income taxes at the statutory rate and provision for income taxes on continuing operations

The reconciliation between U.S. federal income taxes at the statutory rate and the Company's provision for income taxes on continuing operations for the years ended September 27, 2013, September 28, 2012 and September 30, 2011 is as follows ($ in millions):



	For the Years Ended
	September 27, 2013			September 28, 2012			September 30, 2011
Notional U.S. federal income tax expense at the statutory rate	$	206		$	(24	)	$	233
Adjustments to reconcile to the income tax provision:
U.S. state income tax provision, net	(3		)	6			10
Non U.S. net earnings⁽¹⁾	(187		)	17			(94		)
Nondeductible charges	78			61			(18		)
Valuation allowance	4			235			(3		)
Other	10			25			(16		)
Provision for income taxes	$	108		$	320		$	112

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⁽¹⁾	Excludes nondeductible charges and other items which are broken out separately in the table.

Components of the net deferred income tax asset

The components of the net deferred income tax asset as of September 27, 2013 and September 28, 2012 are as follows ($ in millions):



	As of
	September 27, 2013			September 28, 2012
Deferred tax assets:
Accrued liabilities and reserves	$	285		$	52
Tax loss and credit carryforwards	2,432			2,238
Postretirement benefits	183			254
Deferred revenue	111			136
Other	102			381
	3,113			3,061
Deferred tax liabilities:
Property, plant and equipment	(132		)	(126		)
Intangibles assets	(566		)	(497		)
Other	(167		)	(101		)
	(865		)	(724		)
Net deferred tax asset before valuation allowance	2,248			2,337
Valuation allowance	(1,948		)	(1,826		)
Net deferred tax asset	$	300		$	511

Reconciliation of the beginning and ending amount of unrecognized tax benefit

A rollforward of unrecognized tax benefits as of September 27, 2013, September 28, 2012 and September 30, 2011 is as follows ($ in millions):



	As of
	September 27, 2013			September 28, 2012			September 30, 2011
Balance as of beginning of year	$	120		$	144		$	134
Additions based on tax positions related to the current year	137			18			9
Additions based on tax positions related to prior years	7			7			31
Reductions based on tax positions related to prior years	(6		)	(38		)	(27		)
Reductions related to settlements	—			(1		)	(3		)
Reductions related to lapse of the applicable statute of limitations	(2		)	(3		)	(6		)
Foreign currency translation adjustments	—			(7		)	6
Balance as of end of year	$	256		$	120		$	144

Disclosure of income tax examinations

Open tax years in significant jurisdictions are as follows:



Jurisdiction ⁽¹⁾	Years Open To Audit
Australia	2004-2012
Canada	2002-2012
Germany	2005-2012
Switzerland	2003-2012
United Kingdom	2011-2012
United States	1997-2012

Summary of net receivables and liabilities related to the 2012 and 2007 Tax Sharing Agreements

The receivables and liabilities related to the 2012 and 2007 Tax Sharing Agreements as of September 27, 2013 and September 28, 2012 are as follows ($ in millions):



	2012 Tax Sharing Agreement						2007 Tax Sharing Agreement
	As of September 27, 2013			As of September 28, 2012			As of September 27, 2013			As of September 28, 2012
Net receivable:
Prepaid expenses and other current assets	$	—		$	—		$	—		$	9
Other assets	—			—			67			66
	—			—			67			75
Tax sharing agreement related liabilities
Accrued and other current liabilities	(33		)	—			(130		)	(14		)
Other liabilities	(36		)	(71		)	(254		)	(394		)
	(69		)	(71		)	(384		)	(408		)
Net liability	$	(69	)	$	(71	)	$	(317	)	$	(333	)

Income (loss) in conjunction with Tax Sharing Agreements

The Company recorded income (loss) in conjunction with the 2012 and 2007 Tax Sharing Agreements for the years ended September 27, 2013, September 28, 2012 and September 30, 2011 as follows ($ in millions):



	For the Years Ended
	September 27, 2013			September 28, 2012			September 30, 2011
(Expense)/income
2007 Tax Sharing Agreement	$	—		$	(4	)	$	(7	)
2012 Tax Sharing Agreement	(32		)	—			NA

- Definition

Tabular disclosure of tax positions taken in the tax returns filed or to be filed for which it is more likely than not that the tax position will not be sustained upon examination by taxing authorities (i.e., uncertain tax positions) and other types of income tax contingencies, including: (1) the policy on classification of interest and penalties; (2) a tabular reconciliation of the total amounts of unrecognized tax benefits at the beginning and end of the period; the total amount(s) of: (3) unrecognized tax benefits that, if recognized, would affect the effective tax rate, and (4) interest and penalties recognized in each of the income statement and balance sheet; (5) for positions for which it is reasonably possible that the total amounts unrecognized will significantly change within 12 months of the reporting date the: (i) nature of the uncertainty, (ii) nature of the event that could occur that would cause the change, and (iii) an estimate of the range of the reasonably possible change or a statement that an estimate of the range cannot be made; and (6) a description of tax years that remain subject to examination by major tax jurisdictions.

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