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Income Taxes
6 Months Ended
Jun. 30, 2013
Income Taxes

13. Income Taxes

During the second quarter of 2013, we determined that certain deferred tax assets associated with U.S. future foreign tax credits no longer met the “more-likely-than-not” test regarding the realization of those assets primarily due to lower forecasted foreign earnings. Accordingly, the Company increased the valuation allowance against its U.S. future foreign tax credit assets, resulting in a discrete adjustment to the income tax provision in the amount of $6.9 million. As of June 30, 2013 and December 31, 2012, valuation allowances of $9.4 million and $1.9 million, respectively, were recorded against the Company’s net deferred tax assets. We have not established a valuation allowance for any of our other deferred tax assets as we expect that future taxable income as well as the reversal of temporary differences will enable us to fully utilize our deferred tax assets.

As of June 30, 2013, all of the Company’s undistributed non-U.S. subsidiary earnings are considered permanently invested. Accordingly, as of June 30, 2013, we have not provided for deferred taxes on $15.7 million of the undistributed non-U.S. subsidiary earnings. A deferred tax liability will be recognized if and when the Company is no longer able to demonstrate that it plans to permanently reinvest undistributed earnings. If these earnings were repatriated, the Company would be subject to U.S. income taxes. The amount of the unrecognized deferred U.S. income tax liability associated with the indefinitely reinvested undistributed earnings is estimated to be approximately $5.5 million as of June 30, 2013.

Our liability for uncertain tax positions was $2.3 million and $3.8 million at June 30, 2013 and December 31, 2012, respectively. During the first quarter of 2013, the Company effectively settled certain prior year tax matters. As a result, the Company reversed approximately $2.2 million of its liability for uncertain tax positions.

 

The Company has estimated its annual effective tax rate for the full fiscal year 2013 and applied that rate to its income before income taxes in determining its provision for income taxes for the three and six months ended June 30, 2013. The Company also records discrete items in each respective period as appropriate. For the three months ended June 30, 2013, the Company recorded net discrete adjustments of $7.1 million to the income tax provision that resulted in an effective tax rate of 49.8%, as compared to an effective tax rate of 31.3% for the three months ended June 30, 2012. Excluding the impact of this item, the Company’s effective tax rate would have been 34.6%. For the six months ended June 30, 2013, the Company recorded net discrete adjustments of $4.6 million to the income tax provision that resulted in an effective tax rate of 41.3%, as compared to an effective tax rate of 35.0% for the six months ended June 30, 2012. Excluding the impact of these items, the Company’s effective tax rate would have been 35.6%.