Note 15: Income Taxes


	Years ended December 31,
	2014			2013			2012
	(In thousands)
Income (loss) from continuing operations before taxes:
United States operations	$	14,042		$	31,678		$	(22,533	)
Foreign operations		67,504			95,371			27,575

Income from continuing operations before taxes	$	81,546		$	127,049		$	5,042

Income tax expense (benefit):
Currently payable
United States federal	$	6,701		$	(4,493	)	$	(6,945	)
United States state and local		1,617			(26	)		(2,519	)
Foreign		16,592			21,377			14,020

		24,910			16,858			4,556
Deferred
United States federal		(9,662	)		3,575			(22,660	)
United States state and local		(746	)		1,593			(424	)
Foreign		(7,388	)		289			(19,666	)

		(17,796	)		5,457			(42,750	)

Income tax expense (benefit)	$	7,114		$	22,315		$	(38,194	)

In addition to the above income tax expense (benefit) associated with continuing operations, we also recorded income tax expense (benefit) associated with discontinued operations of ($0.9 million), $1.4 million, and $78.7 million in 2014, 2013, and 2012, respectively.


	Years Ended December 31,
	2014			2013			2012
Effective income tax rate reconciliation from continuing operations:
United States federal statutory rate		35.0	%		35.0	%		35.0	%
State and local income taxes		0.8	%		1.5	%		(10.7	%)
Impact of change in deferred tax asset valuation allowance		4.7	%		(0.6	%)		(187.8	%)
Impact of change in tax contingencies		(7.1	%)		3.8	%		3.3	%
Impact of change in United States tax legislation		0.0	%		(3.3	%)		0.0	%
Foreign income tax rate differences		(17.6	%)		(12.1	%)		(278.1	%)
Federal and state impact of Cooper liability settlement		0.0	%		0.0	%		(416.5	%)
Domestic permanent differences & tax credits		(7.1	%)		(6.7	%)		97.3	%

		8.7	%		17.6	%		(757.5	%)

In both 2014 and 2013, the most significant difference between the U.S. federal statutory tax rate and our effective tax rate was the impact of foreign tax rate differences. The statutory tax rates associated with our foreign earnings are generally lower than the statutory U.S. tax rate of 35%. The foreign tax rate differences are most significant in Germany, Canada, and the Netherlands, which have statutory tax rates of approximately 28%, 26%, and 25%, respectively. In 2014, our income tax expense was reduced by $2.0 million due to a tax holiday for our operations in St. Kitts. The tax holiday in St. Kitts is scheduled to expire in 2022.

With respect to the effective income tax rate reconciliation for 2012, the individual percentages reflected are significant due to the dollar value of such items relative to the $5.0 million of consolidated pre-tax income in 2012. The most significant factors impacting the rate and the total income tax benefit of $38.2 million in 2012 include the Cooper Industries tax agreement settlement and the reduction of the deferred tax asset valuation allowance, both of which are discussed further below.

Deferred income taxes have been established for differences in the basis of assets and liabilities for financial statement and tax reporting purposes. For 2012, these amounts included adjustments for a tax sharing agreement with Cooper Industries (Cooper). This agreement required us to pay Cooper the majority of the tax benefits resulting from basis adjustments arising from the initial public offering of our stock on October 6, 1993. The effect of the Cooper tax agreement was to put us in the same financial position we would have been in had there been no increase in the tax basis of our intangible assets (except for a retained 10% benefit). In 2011, Cooper sued us in Texas state court for amounts allegedly owed by us under the tax sharing agreement. As a result of a final settlement reached with Cooper in 2012, the tax sharing agreement has been terminated. We paid a final settlement amount of $30 million in 2013 and recorded a tax benefit of $21.0 million in our 2012 tax provision.

In 2012, we also recorded a $9.5 million tax benefit due to a net reduction in valuation allowances associated with our ability to realize deferred tax assets related to net operating losses and tax credits in various jurisdictions. We evaluated and assessed the expected utilization of net operating losses, future book and taxable income, available tax planning strategies, and our overall deferred tax position to determine the appropriate amount and timing of valuation allowance adjustments. As a result of changes in our business, available tax planning strategies, and future taxable income projections, we determined that the weight of evidence regarding the future realizability of the deferred tax assets had become predominately positive and realization of the deferred tax assets was more likely than not.


	December 31,
	2014			2013
	(In thousands)
Components of deferred income tax balances:
Deferred income tax liabilities:
Plant, equipment, and intangibles	$	(90,414	)	$	(97,229	)
Deferred income tax assets:
Postretirement, pensions, and stock compensation		34,656			27,592
Reserves and accruals		44,809			33,788
Net operating loss and tax credit carryforwards		217,902			88,307
Valuation allowances		(157,317	)		(10,165	)

		140,050			139,522

Net deferred income tax asset	$	49,636		$	42,293

The increase in deferred income tax assets and valuation allowances during 2014 stems primarily from an increase of deferred tax assets associated with net operating losses and related valuation allowances from our acquisition of Grass Valley. We acquired deferred tax assets of approximately $143.5 million associated with net operating losses of Grass Valley. Due to Grass Valley’s history of significant tax losses, both in the U.S. and in various foreign jurisdictions, we recorded a complete valuation allowance of $143.5 million for the acquired net operating losses as part of the purchase price allocation. During 2014, we recorded approximately $4.3 million of income tax expense in order to record a valuation allowance for net operating losses generated by Grass Valley subsequent to the acquisition date. We do not currently have forecasted sources of taxable income in Grass Valley’s jurisdictions that would be sufficient to utilize their net operating losses.

As of December 31, 2014, we had $652.1 million of net operating loss carryforwards and $57.0 million of tax credit carryforwards. Unless otherwise utilized, net operating loss carryforwards will expire upon the filing of the tax returns for the following respective years: $22.5 million in 2014, $30.4 million in 2015, $13.1 million in 2016, $37.3 million between 2017 and 2019, and $188.0 million between 2020 and 2034. Net operating losses with an indefinite carryforward period total $360.8 million. Of the $652.1 million in net operating loss carryforwards, we have determined, based on the weight of all available evidence, both positive and negative, that we will utilize $137.4 million of these net operating loss carryforwards within their respective expiration periods.

Unless otherwise utilized, tax credit carryforwards of $54.5 million will expire as follows: $27.4 million between 2018 and 2020, $3.4 million between 2023 and 2024, and $23.7 million between 2027 and 2034. Tax credit carryforwards with an indefinite carryforward period total $2.5 million. We have determined, based on the weight of all available evidence, both positive and negative, that we will utilize all of these tax credit carryforwards within their respective expiration periods.

The following tables summarize our net operating loss carryforwards and tax credit carryforwards as of December 31, 2014 by jurisdiction:


	Net Operating Loss Carryforwards
	(In thousands)
France	$	272,351
United States - various states		188,178
Netherlands		73,828
Germany		59,761
Japan		27,410
Australia		15,901
Other		14,658

Total	$	652,087


	Tax Credit Carryforwards
	(In thousands)
United States	$	35,261
Canada		21,758

Total	$	57,019

In general, it is our practice and intention to reinvest the earnings of our non-U.S. subsidiaries in those operations. As a result, as of December 31, 2014, we have not made a provision for U.S. or additional foreign withholding taxes on approximately $582.6 million of the undistributed earnings of foreign subsidiaries that are considered permanent in duration. Generally, such amounts become subject to U.S. taxation upon the remittance of dividends and under certain other circumstances. It is not practical to estimate the amount of the deferred tax liability related to investments in these foreign subsidiaries that would be payable if we were not indefinitely reinvested.

In 2014, we recognized a net $8.6 million decrease to reserves for uncertain tax positions. A reconciliation of the beginning and ending amounts of unrecognized tax benefits is as follows:


	2014			2013
	(In thousands)
Balance at beginning of year	$	18,639		$	17,377
Additions based on tax positions related to the current year		663			1,932
Additions for tax positions of prior years		73			3,761
Reductions for tax positions of prior years - Settlement		(7,907	)		(2,490	)
Reduction for tax positions of prior years - Statute of limitations		(1,411	)		(1,941	)

Balance at end of year	$	10,057		$	18,639

The majority of the reductions for tax positions of prior years relates to the settlement of income tax audits in foreign jurisdictions. The balance of $10.1 million at December 31, 2014, reflects tax positions that, if recognized, would impact our effective tax rate.

As of December 31, 2014, we believe it is reasonably possible that $3.8 million of unrecognized tax benefits will change within the next twelve months primarily attributable to the expiration of several statutes of limitations and completion of tax audits in various jurisdictions.

Our practice is to recognize interest and penalties related to uncertain tax positions in interest expense and operating expenses, respectively. During 2014, 2013, and 2012, we recognized approximately ($1.1) million, $1.7 million, and $0.1 million, respectively, in interest expense (reduction of interest expense). We have approximately $1.7 million and $2.8 million accrued for the payment of interest and penalties as of December 31, 2014 and 2013, respectively.

Our federal, state, and foreign income tax returns for the tax years 2007 and later remain subject to examination by the Internal Revenue Service and by various state and foreign tax authorities.