P. INCOME TAXES

The components of income (loss) before income taxes and the provision for income taxes as shown in the consolidated statements of operations were as follows:


	2015			2014			2013
	(in thousands)
Income (loss) before income taxes:
U.S.	$	56,270		$	(151,889	)	$	79,229
Non-U.S.		196,854			247,265			122,693

	$	253,124		$	95,376		$	201,922

Provision (benefit) for income taxes:
Current:
U.S. Federal	$	16,635		$	5,197		$	18,051
Non-U.S.		35,707			28,157			22,509
State		1,429			678			(269	)

		53,771			34,032			40,291

Deferred:
U.S. Federal		(574	)		(20,449	)		(1,692	)
Non-U.S.		(7,761	)		(404	)		(1,386	)
State		1,211			925			(238	)

		(7,124	)		(19,928	)		(3,316	)

Total provision for income taxes:	$	46,647		$	14,104		$	36,975

Income tax expense for 2015, 2014 and 2013 totaled $46.6 million, $14.1 million and $37.0 million, respectively. The effective tax rate for 2015, 2014 and 2013 was 18.4%, 14.8% and 18.3%, respectively. The increase in the effective tax rate from 2014 to 2015 resulted from a shift in the geographic distribution of income which increased income subject to taxation in the United States relative to lower tax rate jurisdictions and a reduction in the benefit from U.S. research and development tax credits. These increases in the effective tax rate were partially offset by decreases associated with uncertain tax positions and a non-deductible goodwill impairment charge. The decrease in the effective tax rate from 2013 to 2014 was primarily attributable to a shift in the geographic distribution of income which decreased income subject to taxation in the United States relative to lower tax rate jurisdictions, partially offset by increases in the effective tax rate associated with uncertain tax positions and a non-deductible goodwill impairment charge.

A reconciliation of the effective tax rate for the years 2015, 2014 and 2013 follows:


	2015			2014			2013
U.S. statutory federal tax rate		35.0	%		35.0	%		35.0	%
Foreign taxes		(16.5	)		(58.1	)		(11.4	)
Goodwill impairment		—			36.3			—
U.S. research and development credit		(3.0	)		(7.9	)		(7.2	)
Uncertain tax positions		2.1			7.9			4.2
Valuation allowance		—			—			0.4
State income taxes, net of federal tax benefit		0.4			(0.1	)		0.1
Other, net		0.4			1.7			(2.8	)

		18.4	%		14.8	%		18.3	%

Teradyne qualifies for a tax holiday in Singapore by fulfilling the requirements of an agreement with the Singapore Economic Development Board under which certain headcount and spending requirements must be met. The tax savings attributable to the tax holiday for the years ended December 31, 2015, 2014 and 2013 were $11.5 million or $0.05 per diluted share, $13.2 million or $0.06 per diluted share and $4.7 million or $0.02 per diluted share, respectively. In December 2015, Teradyne entered into an agreement with the Singapore Economic Development Board which extended the tax holiday under substantially similar terms to the agreement which expired on December 31, 2015. The new tax holiday is scheduled to expire on December 31, 2020.

Significant components of Teradyne’s deferred tax assets (liabilities) as of December 31, 2015 and 2014 were as follows:


	2015			2014
	(in thousands)
Deferred tax assets:
Tax credits	$	44,684		$	50,554
Pension liabilities		31,742			30,036
Inventory valuations		29,445			29,105
Accruals		26,563			23,323
Deferred revenue		10,232			10,242
Equity compensation		9,674			11,131
Net operating loss carryforwards		7,989			10,989
Vacation accrual		7,354			7,425
Other		502			1,725

Gross deferred tax assets		168,185			174,530
Less: valuation allowance		(43,039	)		(41,737	)

Total deferred tax assets	$	125,146		$	132,793

Deferred tax liabilities:
Intangible assets	$	(68,433	)	$	(64,871	)
Depreciation		(20,541	)		(24,905	)
Marketable securities		(458	)		(1,599	)

Total deferred tax liabilities	$	(89,432	)	$	(91,375	)

Net deferred assets	$	35,714		$	41,418

Teradyne records all interest and penalties related to income taxes as a component of income tax expense. Accrued interest and penalties related to income tax items at December 31, 2015 and 2014 amounted to $0.5 million and $0.6 million respectively. For the years ended December 31, 2015, 2014 and 2013, benefit of $0.2 million, expense of $0.2 million and expense of $0.2 million respectively, was recorded for interest and penalties related to income tax items.

During 2015, Teradyne’s valuation allowance increased by $1.3 million primarily due to the increase in the deferred tax assets related to state tax credits generated in 2015.

As of December 31, 2015 and 2014, Teradyne evaluated the likelihood that it would realize the deferred income taxes to offset future taxable income and concluded that it is more likely than not that a substantial majority of its deferred tax assets will be realized through consideration of both the positive and negative evidence. At December 31, 2015 and 2014, Teradyne maintained a valuation allowance for certain deferred tax assets of $43.0 million and $41.7 million, respectively, primarily related to state net operating losses and state tax credit carryforwards, due to the uncertainty regarding their realization. Adjustments could be required in the future if Teradyne estimates that the amount of deferred tax assets to be realized is more or less than the net amount recorded.

At December 31, 2015, Teradyne had operating loss carryforwards that expire in the following years:


	U.S. Federal Operating Loss Carryforwards		State Operating Loss Carryforwards		Foreign Operating Loss Carryforwards
	(in thousands)
2016	$	—	$	925	$	—
2017		—		10,649		—
2018		—		8,563		—
2019		—		1,203		—
2020		—		269		—
2021-2025		4,870		35,777		—
2026-2030		—		39,411		—
Beyond 2030		—		6,359		143
Non-expiring		—		—		8,202

Total	$	4,870	$	103,156	$	8,345

Of the U.S. federal operating loss carryforwards, $4.9 million relates to the acquisition of GenRad, Inc. (“GenRad”) in 2001. GenRad losses are limited in the annual amount that can be used as a result of “change in ownership” rules as defined in the Internal Revenue Code of 1986. The operating loss carryforward does not include any excess tax deduction related to stock based compensation which has not been recognized for financial statement purposes.

Teradyne has approximately $121.2 million of tax credit carryforwards. Federal business tax credits of approximately $43.2 million expire in the years 2017 through 2035. Teradyne has alternative minimum tax credits of approximately $6.6 million, which do not expire. In addition, there are state tax credits of $71.4 million of which $42.4 million do not expire and the remainder of which expires in the years 2016 through 2030. Teradyne has federal tax credits of $42.9 million, that are attributable to stock based compensation deductions which will be recorded as an increase in additional paid in capital on the consolidated balance sheet if and when they are “realized” in accordance with ASC 718-10, “Compensation—Stock Compensation.”

Teradyne’s gross unrecognized tax benefits for the years ended December 31, 2015, 2014 and 2013 were as follows:


	2015			2014			2013
	(in thousands)
Beginning balance, as of January 1	$	30,418		$	21,203		$	18,666
Additions:
Tax positions for current year		6,626			8,414			4,586
Tax positions for prior years		792			3,781			2,112
Reductions:
Tax positions for prior years		(708	)		(2,480	)		(4,161	)
Settlements with tax authorities		(336	)		(500	)		—

Ending balance as of December 31	$	36,792		$	30,418		$	21,203

Current year and prior year additions include assessment of potential transfer pricing issues worldwide, federal and state tax credits and incentives, capitalization rules, and domestic production activities deductions. Reductions for tax positions for prior years primarily relate to statute expiration and the settlement of a foreign tax audit. Of the $36.8 million of unrecognized tax benefits as of December 31, 2015, $29.2 million would impact the consolidated income tax rate if ultimately recognized. The remaining $7.6 million would impact the valuation allowance if recognized. Teradyne estimates that it is reasonably possible that the balance of unrecognized tax benefits as of December 31, 2015 may decrease approximately $7.6 million in the next twelve months, as a result of a lapse of statutes of limitation and the settlement of a tax audit. The estimated decrease is composed primarily of reserves relating to federal tax credits and transfer pricing.

Teradyne is subject to U.S. federal income tax, as well as income tax in multiple state, local and foreign jurisdictions. As of December 31, 2015, all material state and local income tax matters have been concluded through 2008, all material federal income tax matters have been concluded through 2011 and all material foreign income tax matters have been concluded through 2009. However, in some jurisdictions, including the United States, operating losses and tax credits may be subject to adjustment until such time as they are utilized and the year of utilization is closed to adjustment.

As of December 31, 2015, a deferred tax liability has not been established for approximately $783 million of cumulative undistributed earnings of non-U.S. subsidiaries, which are expected to be reinvested indefinitely in operations outside the U.S. except for instances where Teradyne can remit such earnings to the U.S. without an associated net tax cost. Determination of the unrecognized deferred tax liability on unremitted earnings is not practicable due to uncertainty regarding the remittance structure, the mix of earnings and earnings and profit pools in the year of remittance, and overall complexity of the calculation.