INCOME TAXES (Tables)

12 Months Ended

Dec. 31, 2016

Significant components of income taxes attributable to continuing operations

The significant components of income taxes attributable to continuing operations are presented below (in millions):



	2016			2015			2014
Current:
U.S.	$	10.0		$	7.4		$	(62.3	)
Non - U.S.	32.9			50.8			53.5
State	—			0.1			0.1
Current expense (benefit)	42.9			58.3			(8.7		)
Deferred:
U.S.	(20.9		)	(6.3		)	(140.3		)
Non - U.S.	(17.0		)	12.4			(1.7		)
Deferred provision (benefit)	(37.9		)	6.1			(142.0		)
Total provision (benefit)	$	5.0		$	64.4		$	(150.7	)

Income tax expense (benefit), income tax reconciliation

Differences between our provision for income taxes and the amount determined by applying the U.K. statutory rate to income before income taxes are set forth below (dollars in millions):



	2016			2015			2014
U.K. statutory rate	20.00		%	20.25		%	21.50		%
Tax at statutory rate	$	65.1		$	31.9		$	(58.0	)
Increase (decrease) due to:
Capitalized interest transactions	—			(5.7		)	(20.1		)
Tax audit settlements	—			—			10.4
Foreign rate differential	(92.7		)	(30.0		)	38.2
Deferred intercompany gain/loss	(20.1		)	(33.8		)	(86.6		)
Foreign asset basis difference	405.9			—			—
Luxembourg restructuring operating loss	(1,180.2		)	—			—
Change in valuation allowance	814.7			106.0			(3.6		)
Prior period adjustments	(4.1		)	(6.9		)	7.5
Unrecognized tax benefits	7.1			9.7			(35.8		)
U.S. tax on RCI non-U.S. subsidiaries	6.3			—			—
Termination of local country activity	—			(6.3		)	—
Foreign tax credits/deductions	(1.5		)	(2.2		)	(4.9		)
Other, net	4.5			1.7			2.2
Total provision (benefit)	$	5.0		$	64.4		$	(150.7	)

Deferred tax assets and liabilities

Temporary differences and carryforwards which gave rise to deferred tax assets and liabilities at December 31 were as follows (in millions):



	2016			2015
Deferred tax assets:
Accrued employee benefit plan costs	$	81.1		$	137.9
U.S. net operating loss	111.2			27.5
U.K. net operating loss	2.8			2.8
Trinidad net operating loss	6.5			7.7
Luxembourg net operating loss	1,180.2			—
Suriname net operating loss	3.9			—
Interest expense limitation carryforward	—			42.1
Other NOLs and tax credit carryforwards	36.8			33.1
Other	31.2			30.6
Total deferred tax assets	1,453.7			281.7
Less: valuation allowance	(889.8		)	(128.3		)
Deferred tax assets, net of valuation allowance	563.9			153.4

Deferred tax liabilities:
Property and equipment	712.8			296.6
Other	12.3			52.6
Total deferred tax liabilities	725.1			349.2
Net deferred tax asset (liability)	$	(161.2	)	$	(195.8	)

Changes in gross unrecognized tax benefits

The following table sets forth the changes in the Company’s gross unrecognized tax benefits for the years ended December 31 (in millions):



	2016			2015			2014
Gross unrecognized tax benefits - beginning of year	$	65.1		$	54.7		$	81.9
Gross increases - tax positions in prior period	46.2			4.4			19.9
Gross decreases - tax positions in prior period	(0.6		)	(3.7		)	(10.6		)
Gross increases - current period tax positions	10.9			9.7			9.5
Settlements	(1.5		)	—			(37.8		)
Lapse of statute of limitations	—			—			(8.2		)
Gross unrecognized tax benefit - end of year	$	120.1		$	65.1		$	54.7

Schedule of income (loss) before income tax, domestic and foreign

The components of income (loss) from continuing operations before income taxes were as follows (in millions):



	2016			2015			2014
U.S.	$	(180.2	)	$	(174.1	)	$	(198.3	)
Non-U.S.	505.8			331.8			(71.3		)
Total	$	325.6		$	157.7		$	(269.6	)