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Income Taxes
12 Months Ended
Dec. 31, 2015
Income Taxes [Abstract]  
Income Taxes

9  Income Taxes

 

Income tax data for the years ended December 31, 2015, 2014 and 2013 is as follows (in thousands):

    Year Ended December 31,
    2015 2014 2013
The components of income from operations before income taxes are         
 as follows:         
 Domestic $ 66,716 $ 70,136 $ 116,067
 Foreign   475,203   420,604   374,038
  Total $ 541,919 $ 490,740 $ 490,105

    Year Ended December 31,
    2015 2014 2013
The current and deferred components of the provision for income         
 taxes on operations are as follows:         
 Current $ 66,285 $ 57,537 $ 39,933
 Deferred   6,581   1,583   169
  Total $ 72,866 $ 59,120 $ 40,102
            
The jurisdictional components of the provision for income taxes on         
 operations are as follows:         
 Federal $ 20,882 $ 23,071 $ (702)
 State   3,389   3,791   5,142
 Foreign   48,595   32,258   35,662
  Total $ 72,866 $ 59,120 $ 40,102

    Year Ended December 31,
    2015 2014 2013
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 $ 189,672 $ 171,759 $ 171,537
 Settlement of tax audits   (3,258)   -   (30,552)
 State income tax, net of federal income tax benefit   2,601   2,464   3,342
 Net effect of foreign operations   (112,426)   (109,240)   (96,461)
 Other, net   (3,723)   (5,863)   (7,764)
  Provision for income taxes $ 72,866 $ 59,120 $ 40,102

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%, 20.25% and 0%, respectively, as of December 31, 2015. In 2015, the Company entered into a new agreement with Singapore tax authorities that extended a 0% contractual tax rate through March 2021. The contractual tax rate is dependent upon the achievement of certain contractual milestones, which the Company expects to meet. The current statutory tax rate in Singapore is 17%.

 

The Company's effective tax rates for the years ended December 31, 2015, 2014 and 2013 were 13.4%, 12.0% and 8.2%, respectively. The increase in the effective tax rate in 2015 as compared to 2014 can be attributed to differences in the proportionate amounts of pre-tax income recognized in jurisdictions with different effective tax rates. In addition, the income tax provision for 2015 included a $3 million tax benefit related to the completion of tax audit examinations.

 

The increase in the effective tax rate in 2014 as compared to 2013 can be attributed to the fact that 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 remaining differences between the effective tax rates for 2014 and 2013 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,
     2015 2014
Deferred tax assets:      
 Net operating losses and credits $ 83,428 $ 102,810
 Depreciation   8,223   11,979
 Stock-based compensation   18,160   18,702
 Deferred compensation   28,907   34,301
 Revaluation of equity investments   5,396   5,819
 Inventory   4,470   4,104
 Accrued liabilities and reserves   10,129   9,368
 Other   15,871   18,097
  Total deferred tax assets   174,584   205,180
 Valuation allowance   (68,595)   (82,550)
  Deferred tax assets, net of valuation allowance   105,989   122,630
Deferred tax liabilities:      
 Capitalized software   (15,336)   (16,253)
 Amortization   (5,799)   (8,765)
 Indefinite-lived intangibles   (18,924)   (18,094)
  Total deferred tax liabilities   (40,059)   (43,112)
   Net deferred tax assets $ 65,930 $ 79,518

On December 31, 2015, the Company adopted new accounting guidance related to the presentation of deferred tax assets and deferred tax liabilities. The accounting guidance requires that all deferred tax assets and deferred tax liabilities, including any valuation allowances, be classified as long-term in the consolidated balance sheet. The Company elected to apply the adoption of this standard retrospectively and reclassified $36 million of current net deferred tax assets to long-term net deferred tax assets as of December 31, 2014.

 

As of December 31, 2015, the Company has provided a deferred tax valuation allowance of $69 million, of which $64 million relates to certain foreign net operating losses. The Company's net deferred tax assets associated with net operating losses and tax credit carryforwards are approximately $20 million as of December 31, 2015, 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 $13 million, $16 million and $16 million for the years ended December 31, 2015, 2014 and 2013, respectively.

 

At December 31, 2015, 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, 2015, 2014 and 2013 (in thousands):

    2015 2014 2013
Balance at the beginning of the period $ 19,596 $ 24,716 $ 64,390
 Changes resulting from completion of tax examinations   (2,405)   -   (35,279)
 Other changes in uncertain tax benefits   (2,741)   (5,120)   (4,395)
Balance at the end of the period $ 14,450 $ 19,596 $ 24,716

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, 2011. However, carryforward attributes that were generated in years beginning on or before January 1, 2012 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 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.

 

During the year ended December 31, 2015, the Company concluded U.S. tax audit disputes that, in part, related to matters for which the Company had recorded net uncertain tax benefits. The resolution of these tax disputes resulted in a $2 million reduction in the measurement of its unrecognized tax benefits and a $2 million decrease in its provision for income taxes for the year ended December 31, 2015.

 

As of December 31, 2015, 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.