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Income Taxes
3 Months Ended
Sep. 28, 2013
Income Taxes
Income Taxes
The Company recognized income tax expense of $17.3 million and $80.5 million for the three and nine month periods ended September 28, 2013, respectively, resulting in an effective tax rate of 9.3% and 15.1%, respectively. The effective tax rate differs from the U.S. statutory tax rate for the three and nine month periods ended September 28, 2013 primarily due to a portion of the Company's earnings realized in lower-taxed foreign jurisdictions and the acceleration of certain tax credits resulting in a tax benefit of $18.5 million in the quarter, the recurring benefit of various foreign business integration structures and the reversal of certain foreign and U.S. state uncertain tax position reserves, related largely to statute expiration.
The Company recognized income tax expense of $12.9 million and $82.9 million for the three and nine month periods ended September 29, 2012, respectively, resulting in an effective tax rate of 12.5% and 20.3%, respectively. The effective tax rate differs from the statutory tax rate for the three and nine month periods ended September 29, 2012, primarily due to a portion of the Company's earnings realized in lower-taxed foreign jurisdictions, favorable settlement of certain tax contingencies of $6.6 million and the realization of a foreign deferred tax asset attributable to the reduction of a valuation allowance for certain net operating losses resulting in a tax benefit of $7.0 million in the quarter.
During the three months ended September 28, 2013, the Company completed the remaining material 2012 income tax return filings which included the final calculations of the tax gain on the Hardware & Home Improvement business (“HHI”) sale which took place in 2012. As a result of these tax return filings, the Company recorded an income tax benefit of approximately $17.2 million within discontinued operations related to finalization of the taxable gain on the HHI sale. Changes to the original tax gain were driven primarily by the determination of the final purchase price allocation and the finalization of the U.S. tax basis calculation, both of which were finalized in the quarter.
The Company is subject to the examination of its income tax returns by the Internal Revenue Service and other taxing authorities both domestically and internationally. The final outcome of the future tax consequences of these examinations and legal proceedings, as well as, the outcome of competent authority proceedings, changes and interpretation in regulatory tax laws, or expiration of statute of limitations could impact the Company’s financial statements. Accordingly, the Company has tax reserves recorded for which it is reasonably possible that the amount of the unrecognized tax benefit will increase or decrease which could have a material effect on the financial results for any particular fiscal quarter or year. However, based on the uncertainties associated with litigation and the status of examinations, including the protocols of finalizing audits by the relevant tax authorities which could include formal legal proceedings, it is not possible to estimate the impact of any such change.