Income Taxes (Tables)
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12 Months Ended |
Sep. 27, 2013
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Income Tax Disclosure [Abstract] |
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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 |
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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. |
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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 |
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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 |
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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 |
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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 | ) |
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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 |
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