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Income Taxes
12 Months Ended
Dec. 31, 2014
Income Taxes [Abstract]  
Income Taxes

9  Income Taxes

 

Income tax data for the years ended December 31, 2014, 2013 and 2012 is as follows (in thousands):

    Year Ended December 31,
    2014 2013 2012
The components of income from operations before income taxes are         
 as follows:         
 Domestic $ 70,136 $ 116,067 $ 116,071
 Foreign   420,604   374,038   371,554
  Total $ 490,740 $ 490,105 $ 487,625

    Year Ended December 31,
    2014 2013 2012
The current and deferred components of the provision for income         
 taxes on operations are as follows:         
 Current $ 57,537 $ 39,933 $ 78,401
 Deferred   1,583   169   (52,219)
  Total $ 59,120 $ 40,102 $ 26,182
            
The jurisdictional components of the provision for income taxes on         
 operations are as follows:         
 Federal $ 23,071 $ (702) $ 39,840
 State   3,791   5,142   5,599
 Foreign   32,258   35,662   (19,257)
  Total $ 59,120 $ 40,102 $ 26,182
            
The differences between income taxes computed at the United States         
 statutory rate and the provision for income taxes are summarized         
 as follows:         
 Federal tax computed at U.S. statutory income tax rate $ 171,759 $ 171,537 $ 170,669
 Settlement of tax audits   -   (30,552)   (6,035)
 State income tax, net of federal income tax benefit   2,464   3,342   3,639
 Net effect of foreign operations   (109,240)   (96,461)   (102,858)
 Recognition of deferred tax asset associated with a non-U.S.         
   net operating loss   -   -   (36,410)
 Other, net   (5,863)   (7,764)   (2,823)
  Provision for income taxes $ 59,120 $ 40,102 $ 26,182

The four principal jurisdictions in which the Company manufactures are the U.S., Ireland, the United Kingdom and Singapore, where the marginal effective tax rates were approximately 37.5%, 12.5%, 21.5% and 0%, respectively, as of December 31, 2014. The Company has a contractual tax rate in Singapore of 0% through March 2016, based upon achievement of contractual milestones that the Company expects to continue to meet. The current statutory tax rate in Singapore is 17%.

 

The Company's effective tax rates for the years ended December 31, 2014, 2013 and 2012 were 12.0%, 8.2% and 5.4%, respectively. The income tax provision for 2013 included a $31 million net tax benefit related to the completion of tax audit examinations. In addition, the research and development tax credit (“R&D Tax Credit”) was retroactively extended in January 2013 for the 2012 and 2013 tax years. The entire $3 million benefit related to the 2012 tax year was recorded in the first quarter of 2013, and the 2013 benefit was included in the 2013 annual effective tax rate. The net income tax benefits related to the completed tax audit examinations and the 2012 R&D Tax Credit decreased the Company's effective tax rate by 6.9 percentage points in the year ended December 31, 2013. The income tax provision for the year ended December 31, 2012 included a $36 million tax benefit related to the Company's refinancing of certain of its inter-company debt arrangements, which enabled the Company to recognize a deferred tax asset associated with a non-U.S. net operating loss carryforward. During the year ended December 31, 2012, the Company also recorded a $6 million tax benefit related to tax audit settlements in the U.S. These tax benefits decreased the Company's effective tax rate by 8.6 percentage points in the year ended December 31, 2012. The remaining differences between the effective tax rates for 2014, 2013 and 2012 were primarily attributable to differences in the proportionate amounts of pre-tax income recognized in jurisdictions with different effective tax rates.

The tax effects of temporary differences and carryforwards which give rise to deferred tax assets and deferred tax liabilities are summarized as follows (in thousands):

     December 31,
     2014 2013
Deferred tax assets:      
 Net operating losses and credits $ 102,810 $ 116,567
 Depreciation   11,979   7,163
 Stock-based compensation   18,702   22,684
 Deferred compensation   34,301   25,391
 Revaluation of equity investments   5,819   3,832
 Inventory   4,104   3,651
 Accrued liabilities and reserves   9,368   23,268
 Other   18,097   15,289
  Total deferred tax assets   205,180   217,845
 Valuation allowance   (82,550)   (94,952)
  Deferred tax assets, net of valuation allowance   122,630   122,893
Deferred tax liabilities:      
 Capitalized software   (16,253)   (18,012)
 Amortization   (8,765)   (3,798)
 Indefinite-lived intangibles   (18,094)   (18,840)
  Total deferred tax liabilities   (43,112)   (40,650)
   Net deferred tax assets $ 79,518 $ 82,243

The Company's net deferred tax assets included in the consolidated balance sheets are classified as follows (in thousands):

   December 31, 2014 December 31, 2013
Other current assets $ 36,691 $ 31,423
Other assets   61,920   69,466
Other current liabilities   (1,096)   (579)
Other long-term liabilities   (17,997)   (18,067)
 Net deferred tax assets $ 79,518 $ 82,243

During the year ended December 31, 2012, the deferred tax assets associated with net operating losses and tax credit carryforwards and the related valuation allowance increased due to the aforementioned tax benefit related to the Company's refinancing of inter-company debt arrangements. This deferred tax asset was established for $111 million, for which a $75 million valuation allowance was established and a $36 million tax benefit was recorded in the income tax provision.

 

As of December 31, 2014, the Company has provided a deferred tax valuation allowance of $83 million, of which $78 million relates to foreign tax credits and certain foreign net operating losses. The Company's net deferred tax assets associated with net operating losses and tax credit carryforwards are approximately $25 million as of December 31, 2014, which represent the future tax benefit of foreign net operating loss carryforwards that do not expire under current law.

The income tax benefits associated with non-qualified stock option compensation expense recognized for tax purposes and credited to additional paid-in capital were $16 million, $16 million and $11 million for the years ended December 31, 2014, 2013 and 2012, respectively.

 

At December 31, 2014, there were unremitted earnings of foreign subsidiaries of approximately $3 billion. The Company has not provided for U.S. income taxes or foreign withholding taxes on these earnings as it is the Company's current intention to permanently reinvest these earnings outside the U.S. Because of the complexity of U.S. and foreign tax rules applicable to the distribution of earnings from foreign subsidiaries to U.S. legal entities, the determination of the unrecognized deferred tax liability on these earnings is not practicable. Events that could trigger a tax might include U.S. acquisitions or other investments funded by cash distributions or loans from a foreign subsidiary.

The Company accounts for its uncertain tax return reporting positions in accordance with the accounting standards for income taxes, which require financial statement reporting of the expected future tax consequences of uncertain tax reporting positions on the presumption that all concerned tax authorities possess full knowledge of those tax reporting positions, as well as all of the pertinent facts and circumstances, but prohibit any discounting of unrecognized tax benefits associated with those reporting positions for the time value of money.

The following is a summary of the activity of the Company's unrecognized tax benefits for the years ended December 31, 2014, 2013 and 2012 (in thousands):

    2014 2013 2012
Balance at the beginning of the period $ 24,716 $ 64,390 $ 73,199
 Realization of uncertain U.S. tax benefits   -   -   (5,625)
 Changes resulting from completion of tax examinations   -   (35,279)   -
 Other changes in uncertain tax benefits   (5,120)   (4,395)   (3,184)
Balance at the end of the period $ 19,596 $ 24,716 $ 64,390

With limited exceptions, the Company is no longer subject to tax audit examinations in significant jurisdictions for the years ended on or before December 31, 2009. However, carryforward attributes that were generated in years beginning on or before January 1, 2010 may still be adjusted upon examination by tax authorities if the attributes are utilized. The Company continuously monitors the lapsing of statutes of limitations on potential tax assessments for related changes in the measurement of unrecognized tax benefits, related net interest and penalties, and deferred tax assets and liabilities.

 

During the year ended December 31, 2013, the Company concluded tax audit disputes with tax authorities in the U.S. and Japan that were related to matters for which the Company had previously recorded uncertain tax benefits of approximately $35 million. The resolution of these tax audit disputes also entailed net global assessments against the Company of approximately $4 million. Accordingly, the Company recorded a $35 million reduction in the measurement of its unrecognized tax benefits and a $4 million increase in its current tax liabilities in the year ended December 31, 2013, which reduced the provision for income taxes and increased net income for the year ended December 31, 2013 by $31 million. As of December 31, 2014, the Company expects to record additional reductions in the measurement of its unrecognized tax benefits and related net interest and penalties of approximately $5 million within the next twelve months due to the lapsing of statutes of limitations on potential tax assessments. The Company does not expect to record any other material reductions in the measurement of its unrecognized tax benefits within the next twelve months.