14. Income Taxes

For financial reporting purposes, income before income taxes includes the following components (in thousands):


	Years Ended December 31,
	2016		2015		2014
United States	$	134,740	$	52,563	$	47,963
Foreign		50,841		60,810		50,806

Total	$	185,581	$	113,373	$	98,769

The expense (benefit) for income taxes consists of the following (in thousands):


	Years Ended December 31,
	2016			2015			2014
Federal
Current	$	14,108		$	(6,889	)	$	7,895
Deferred		19,034			18,024			7,021

Total		33,142			11,135			14,916
State
Current		12,565			379			1,542
Deferred		(2,502	)		(4,096	)		(2,397	)

Total		10,063			(3,717	)		(855	)
Foreign
Current		11,671			15,117			13,335
Deferred		1,170			5,402			3,813

Total		12,841			20,519			17,148

Total	$	56,046		$	27,937		$	31,209

Differences between the income tax expense computed at the statutory federal income tax rate and per the consolidated statements of income are summarized as follows (in thousands):


	Years Ended December 31,
	2016			2015			2014
Tax expense at federal rate of 35%	$	64,953		$	39,680		$	34,569
State income taxes, net of federal benefit		7,060			(2,462	)		(544	)
Change in valuation allowance		(8,524	)		(9,066	)		3,521
Foreign tax rate differential		(11,830	)		(5,710	)		(5,508	)
Unrecognized tax benefit increase		1,045			2,977			65
Tax effect of foreign operations		5,988			261			(104	)
Acquisition costs		28			—			289
Tax benefit of research & development		(1,088	)		(871	)		(3,446	)
Other		(1,586	)		3,128			2,367

Income tax provision	$	56,046		$	27,937		$	31,209

The countries having the greatest impact on the tax rate adjustment line shown in the above table as “Foreign tax rate differential” for the year ended December 31, 2016 are Ireland, South Africa, and the United Kingdom. The countries having the greatest impact on the tax rate adjustment line shown in the above table as “Foreign tax rate differential” for the year ended December 31, 2015 are Ireland, Netherlands, South Africa, and the United Kingdom. The countries having the greatest impact on the tax rate adjustment line shown in the above table as “Foreign tax rate differential” for the year ended December 31, 2014 are Ireland, South Africa, and the United Kingdom.

The deferred tax assets and liabilities result from differences in the timing of the recognition of certain income and expense items for tax and financial accounting purposes. The sources of these differences at each balance sheet date are as follows (in thousands):


	December 31,
	2016			2015
Deferred income tax assets:
Net operating loss carryforwards	$	65,351		$	112,193
Tax credits		25,173			40,614
Compensation		39,340			25,752
Deferred revenue		27,303			25,287
Other		6,279			8,346

Gross deferred income tax assets		163,446			212,192
Less: valuation allowance		(9,659	)		(18,742	)

Net deferred income tax assets	$	153,787		$	193,450

Deferred income tax liabilities:
Depreciation and amortization	$	(102,657	)	$	(130,645	)

Total deferred income tax liabilities		(102,657	)		(130,645	)

Net deferred income taxes	$	51,130		$	62,805

Deferred income taxes / liabilities included in the balance sheet are:
Deferred income tax asset—noncurrent	$	77,479		$	90,872
Deferred income tax liability—noncurrent		(26,349	)		(28,067	)

Net deferred income taxes	$	51,130		$	62,805

In assessing the realizability of deferred tax assets, the Company considers whether it is more likely than not that some portion or all of the deferred tax assets will not be realized. The ultimate realization of deferred tax assets is dependent upon the generation of future taxable income during the periods in which those temporary differences become deductible. The Company considers projected future taxable income, carryback opportunities, and tax planning strategies in making this assessment. Based upon the level of historical taxable income and projections for future taxable income over the periods which the deferred tax assets are deductible, the Company believes it is more likely than not that it will realize the benefits of these deductible differences, net of the valuation allowances recorded. During the year ended December 31, 2016, the Company decreased its valuation allowance by $9.1 million which relates primarily to a reduction in valuation allowance on U.S. foreign tax credits.

At December 31, 2016, the Company had domestic federal tax net operating losses (“NLs”) of $139.7 million which will begin to expire in 2017. The Company had deferred tax asset equal to $6.4 million related to domestic state tax NOLs which will begin to expire in 2017. The Company does not have any valuation allowance against the federal tax NOLs, but has provided a $5.9 million valuation allowance against the tax benefit associated with the state NOLs. The Company had foreign tax NOLs of $37.3 million, of which $35.9 million may be utilized over an indefinite life, with the remainder expiring over the next 10 years. The Company has provided a $1.2 million valuation allowance against the tax benefit associated with the foreign NOLs.

The Company had U.S. foreign tax credit carryforwards at December 31, 2016 of $17.3 million, for which a $0.6 million valuation allowance has been provided. The U.S. foreign tax credits will begin to expire in 2021. The Company also had domestic federal and state general business credit carryforwards at December 31, 2016 of $11.9 million and $0.5 million, respectively, which will begin to expire in 2019 and 2022, respectively.

The unrecognized tax benefit at December 31, 2016 and 2015 was $24.3 million and $21.1 million, respectively, of which $17.6 million and $8.2 million, respectively, are included in other noncurrent liabilities in the consolidated balance sheet. Of the total unrecognized tax benefit amounts at December 31, 2016 and 2015, $23.2 million and $20.0 million, respectively, represent the net unrecognized tax benefits that, if recognized, would favorably impact the effective income tax rate in respective years.

A reconciliation of the beginning and ending amount of unrecognized tax benefits for the years ended December 31 is as follows (in thousands):


	2016			2015			2014
Balance of unrecognized tax benefits at beginning of year	$	21,079		$	14,780		$	14,996
Increases for tax positions of prior years		58			1,449			84
Decreases for tax positions of prior years		(361	)		(47	)		(412	)
Increases for tax positions established for the current period		5,185			9,866			491
Decreases for settlements with taxing authorities		(167	)		(594	)		—
Reductions resulting from lapse of applicable statute of limitation		(1,310	)		(4,218	)		(239	)
Adjustment resulting from foreign currency translation		(206	)		(157	)		(140	)

Balance of unrecognized tax benefits at end of year	$	24,278		$	21,079		$	14,780

The Company files income tax returns in the U.S. federal jurisdiction, various state and local jurisdictions, and many foreign jurisdictions. The United States, Australia, Canada, India, Ireland, Luxembourg, South Africa, and United Kingdom are the main taxing jurisdictions in which the Company operates. The years open for audit vary depending on the tax jurisdiction. In the United States, the Company’s tax returns for years following 2012 are open for audit. In the foreign jurisdictions, the tax returns open for audit generally vary by jurisdiction between 2002 and 2015.

The Company’s Indian income tax returns covering fiscal years 2002 through 2006 and 2010 through 2014 are under audit by the Indian tax authority. Other foreign subsidiaries could face challenges from various foreign tax authorities. It is not certain that the local authorities will accept the Company’s tax positions. The Company believes its tax positions comply with applicable tax law and intends to vigorously defend its positions. However, differing positions on certain issues could be upheld by tax authorities, which could adversely affect the Company’s financial condition and results of operations.

The Company believes it is reasonably possible that the total amount of unrecognized tax benefits will decrease within the next 12 months by approximately $1.4 million due to the settlement of various audits and the expiration of statutes of limitations. The Company accrues interest related to uncertain tax positions in interest expense or interest income and recognizes penalties related to uncertain tax positions in other income or other expense. As of December 31, 2016 and 2015, $1.9 million and $2.2 million, respectively is accrued for the payment of interest and penalties related to income tax liabilities. The aggregate amount of interest and penalties recorded in the statement of income for the years ended December 31, 2016, 2015, and 2014 is $(0.2) million, $(0.1) million and $0.2 million, respectively.

The undistributed earnings of the Company’s foreign subsidiaries of approximately $181.9 million are considered to be permanently reinvested. Accordingly, no provision for U.S. federal and state income taxes or foreign withholding taxes has been provided for such undistributed earnings. The determination of the additional U.S. federal and state income taxes or foreign withholding taxes that have not been provided is not practicable.