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Income Taxes
12 Months Ended
Dec. 31, 2016
Income Tax Disclosure [Abstract]  
Income Taxes
Income Taxes


The provision for income taxes was as follows:
Year Ended December 31
2016

2015

2014

Current
 
 
 
United States
 
 
 
Federal

$35.6


($8.4
)

$44.8

State
4.0


7.0

Non-United States
144.0

158.7

148.2

Total current
183.6

150.3

200.0

Deferred
 
 
 
United States
 
 
 
Federal
69.7

92.9

53.2

State
0.5

1.8

(1.9
)
Non-United States
3.8

(3.5
)
2.7

Total deferred
74.0

91.2

54.0

Total provision

$257.6


$241.5


$254.0

 
 
 
 


A reconciliation between taxes computed at the United States Federal statutory rate of 35% and the consolidated effective tax rate is as follows:
Year Ended December 31
2016

2015

2014

Income tax based on statutory rate

$245.5


$231.2


$238.6

Increase (decrease) resulting from:
 
 
 
Non-United States tax rate difference
17.5

20.4

20.1

Repatriation of non-United States earnings
(10.5
)
(16.9
)
(10.1
)
State income taxes, net of Federal benefit
2.2

2.7

2.9

Change in valuation allowance
(6.0
)
3.3

5.0

Other, net
8.9

0.8

(2.5
)
Tax provision

$257.6


$241.5


$254.0

 
 
 
 


Included in non-United States tax rate difference are benefits of $1.8, $1.5 and $2.8 for 2016, 2015 and 2014, respectively, related to the French CICE payroll tax credit because the CICE credit is tax-free for French tax purposes. The tax benefits related to the CICE credit in excess of these amounts are offset by related increases in United States tax expense. For United States tax purposes, certain French earnings impacted by the CICE credit are treated as a deemed dividend in the current year or future years, resulting in an increase in United States tax expense.


Deferred income taxes are recorded on temporary differences at the tax rate expected to be in effect when the temporary differences reverse. Temporary differences, which gave rise to the deferred taxes, were as follows:
December 31
2016

2015

Future Income Tax (Expense) Benefits
 
 
Accrued payroll taxes and insurance

$30.6


$31.5

Employee compensation payable
26.6

31.7

Pension and postretirement benefits
60.7

57.5

Intangible assets
(146.8
)
(144.7
)
Repatriation of non-United States earnings
(164.8
)
(132.0
)
Intercompany loans denominated in foreign currencies
(74.2
)
(61.2
)
Net operating losses
92.7

106.5

Other
120.7

133.1

Valuation allowance
(86.3
)
(95.9
)
Total future tax expense

($140.8
)

($73.5
)
Deferred tax asset
81.4

83.9

Deferred tax liability
(222.2
)
(157.4
)
Total future tax expense

($140.8
)

($73.5
)
 
 
 


We had United States Federal and non-United States net operating loss carryforwards and United States state net operating loss carryforwards totaling $350.0 and $256.8, respectively, as of December 31, 2016. The net operating loss carryforwards expire as follows:
 
United States Federal
and Non-United States

United States
State

2017

$1.1


$3.8

2018
1.3

5.5

2019
7.0

3.8

2020
3.3


2021
4.4


Thereafter
23.4

243.7

No expirations
309.5


Total net operating loss carryforwards

$350.0


$256.8



We have recorded a deferred tax asset of $92.7 as of December 31, 2016, for the benefit of these net operating losses. Realization of this asset is dependent on generating sufficient taxable income prior to the expiration of the loss carryforwards. A related valuation allowance of $75.9 has been recorded as of December 31, 2016, as management believes that realization of certain net operating loss carryforwards is unlikely.

Pre-tax earnings of non-United States operations were $482.2, $511.2 and $485.9 in 2016, 2015 and 2014, respectively. We have not provided United States income taxes or non-United States withholding taxes on $555.3 of unremitted earnings of non-United States subsidiaries that are considered to be permanently invested. As of December 31, 2016, deferred taxes are provided on $774.7 of unremitted earnings of non-United States subsidiaries that may be remitted to the United States. As of December 31, 2016 and 2015, we have recorded a deferred tax liability of $164.8 and $132.0, respectively, related to these non-United States earnings that may be remitted.

As of December 31, 2016, we had gross unrecognized tax benefits related to various tax jurisdictions, including interest and penalties, of $44.0 that would favorably affect the effective tax rate if recognized. Our unrecognized tax benefits may decrease over the next 12 months pending resolution of certain tax audits during this time.






As of December 31, 2015, we had gross unrecognized tax benefits related to various tax jurisdictions, including interest and penalties, of $38.9.

We recognize accrued interest and penalties related to unrecognized tax benefits in income tax expense. We accrued net interest and penalties of $0.3 and $12.1 in 2016 and 2015, respectively, and recorded a benefit of $0.6 in 2014.

The following table summarizes the activity related to our unrecognized tax benefits during 2016, 2015 and 2014:
 
2016

2015

2014

Gross unrecognized tax benefits, beginning of year

$19.0


$23.0


$23.9

Increases in prior year tax positions
4.1

2.3

0.7

Decreases in prior year tax positions
(1.7
)
(0.5
)
(1.2
)
Increases for current year tax positions
4.1

3.1

2.2

Expiration of statute of limitations and audit settlements
(1.7
)
(8.9
)
(2.6
)
Gross unrecognized tax benefits, end of year

$23.8


$19.0


$23.0

Potential interest and penalties
20.2

19.9

7.8

Balance, end of year

$44.0


$38.9


$30.8

 
 
 
 


We conduct business globally in various countries and territories. We are routinely audited by the tax authorities of the various tax jurisdictions in which we operate. Generally, the tax years that could be subject to examination are 2009 through 2016 for our major operations in France, Germany, Japan, the United Kingdom and the United States. As of December 31, 2016, we were subject to tax audits in Austria, Canada, Denmark, Germany, Italy, Portugal and the United States. We believe that the resolution of these audits will not have a material impact on earnings.