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Income Taxes
9 Months Ended
Sep. 26, 2014
Income Tax Disclosure [Abstract]  
Income Taxes
Income Taxes
The Company’s effective tax rate for the three months ended September 26, 2014 and September 27, 2013 was 3.6% and 68.9% respectively. The low effective tax rate for the three months ended September 26, 2014 was primarily due to the combined impact of no tax benefits being available for the $14.1 million Venezuelan currency revaluation loss, recording a relatively small $2.3 million tax benefit on $119.6 million of asset-related costs and restructuring charges, and the impact of full year forecasted operational losses incurred in jurisdictions where valuation allowances are recorded against net deferred tax assets.  These unfavorable effective tax rate drivers were partially offset by an $8.0 million income tax benefit associated with uncertain tax position reserve releases during the three months ended September 26, 2014. The effective tax rate for the three months ended September 27, 2013 was negatively influenced by the impact of recording no tax benefit on full year forecasted losses in jurisdictions where valuation allowances were recorded against deferred tax assets. 
The Company’s effective tax rate for the nine months ended September 26, 2014 and September 27, 2013 was 2.8% and 1,758.8% respectively. The low effective tax rate on the pre-tax loss for the nine months ended September 26, 2014 was primarily due to a relatively small income tax benefit recorded on the significant pre-tax charges related to asset impairments, restructuring charges, Venezuela currency devaluation loss, and other operational losses incurred in jurisdictions where valuation allowances are recorded against net deferred tax assets.  In the first quarter, a $19.9 million income tax benefit was recognized due to the reversal of deferred tax liabilities associated with the $93.4 million PDIC trade name impairment charge, a $0.1 million income tax benefit was recognized on the $155.1 million PDIC goodwill impairment charge, no income tax benefit was recognized on the $8.8 million Venezuela lower of cost or market inventory charge, and no income tax benefit was recognized related to the $83.1 million Venezuelan currency devaluation charge. In the second and third quarters, a $2.8 million income tax benefit was recorded on $146.3 million of asset-related costs and restructuring charges and no tax benefit was recognized related to the $11.6 million of net Venezuelan currency revaluation losses. These unfavorable effective tax rate drivers were partially offset by $14.7 million of uncertain tax position reserve releases recorded in nine months ended September 26, 2014. The extremely high effective tax rate on the pre-tax income for the nine months ended September 27, 2013 reflects the combined impact of the small $1.7 million pre-tax income, no tax benefit on the Venezuelan currency devaluation loss, the greater mix of earnings in high tax jurisdictions, and the impact of full year forecasted losses in jurisdictions where valuation allowances were recorded against deferred tax assets.
During the third quarter of 2014, the Company accrued approximately $1.3 million of income tax expense for uncertain tax positions likely to be taken in the current year and for interest and penalties on tax positions taken in prior periods, all of which would have a favorable impact on the effective tax rate, if recognized. In addition, $8 million of income tax benefits were recognized due to statute of limitation expirations associated with various uncertain tax positions.

The Company files income tax returns in numerous tax jurisdictions around the world. Due to uncertainties regarding the timing and outcome of various tax audits, appeals and settlements, it is difficult to reliably estimate the amount of unrecognized tax benefits that could change within the next twelve months. The Company believes it is reasonably possible that approximately $9 million of unrecognized tax benefits could change within the next twelve months due to the resolution of tax audits and statute of limitations expiration.

The Internal Revenue Service ("IRS") currently is in the process of examining the Company's 2012 consolidated income tax return.  The IRS completed its examination of the Company's 2007 through 2010 consolidated income tax returns in the second quarter of 2013 with insignificant tax adjustments.  With limited exceptions, tax years prior to 2009 are no longer open in major foreign, state, or local tax jurisdictions.