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Income Taxes
12 Months Ended
Dec. 31, 2022
Income Tax Disclosure [Abstract]  
Income Taxes
10     Income Taxes
Income tax data for the years ended December 31, 2022, 2021 and 2020 is as follows (in
thousands):
 
 
  
Year Ended December 31,
 
 
  
2022
 
  
2021
 
  
2020
 
The components of income before income taxes are as follows:
                          
Domestic
   $ 133,816      $ 144,410      $ 75,193  
Foreign
     704,030        661,783        535,721  
    
 
 
    
 
 
    
 
 
 
Total
   $ 837,846      $ 806,193      $ 610,914  
    
 
 
    
 
 
    
 
 
 
 
 
  
Year Ended December 31,
 
 
  
2022
 
 
2021
 
  
2020
 
The components of the income tax provision were as follows:
  
  
  
Federal
   $ 62,153      $ 16,302      $ 28,385  
State
     8,025        3,691        4,243  
Foreign
     91,901        76,724        59,408  
    
 
 
    
 
 
    
 
 
 
Total current tax provision
   $ 162,079      $ 96,717      $ 92,036  
    
 
 
    
 
 
    
 
 
 
Federal
   $ (26,551 )    $ 10,491      $ (8,244
State
     (4,420 )      345        (506
Foreign
     (1,017 )      5,797        6,057  
    
 
 
    
 
 
    
 
 
 
Total deferred tax provision
     (31,988 )      16,633        (2,693
    
 
 
    
 
 
    
 
 
 
Total provision
   $ 130,091      $ 113,350      $ 89,343  
    
 
 
    
 
 
    
 
 
 
 
 
The
 
differences between income taxes computed at the United States statutory rate and the provision for income taxes are summarized as follows for the years ended December 31, 2022, 2021 and 2020 (in
thousands):
 
 
  
Year Ended December 31,
 
 
  
2022
 
 
2021
 
 
2020
 
Federal tax computed at U.S. statutory income tax rate
   $ 175,948      $ 169,300      $ 128,292  
GILTI, net of foreign tax credits
     17,812        10,476        13,319  
State income tax, net of federal income tax benefit
     3,605        4,036        2,415  
Net effect of foreign operations
     (54,549 )      (54,566      (48,962
Effect of stock-based compensation
     (7,341 )      (6,682      (6,798
Other, net
     (5,384      (9,214      1,077  
    
 
 
    
 
 
    
 
 
 
Provision for income taxes
   $ 130,091      $ 113,350      $ 89,343  
    
 
 
    
 
 
    
 
 
 
The
 
Company’s effective tax rate w
as
 
15.5
%,
14.1
% and
14.6
% for the years ended December 31, 2022, 2021 and 2020, respectively.
The Company’s effective income tax rate differs from the U.S. federal statutory rate each year due to differences in the proportionate amounts of
pre-tax
income recognized in jurisdictions with different effective tax rates and the items discussed below.
The four principal jurisdictions in which the Company manufactures are the U.S., Ireland, the U.K. and Singapore, where the statutory tax rates were 21%, 12.5%, 19% and 17%, respectively, as of December 31, 2022. The Company has a new Development and Expansion Incentive in Singapore that provides a concessionary income tax rate of 5%
on certain types of income for the period April 1, 2021 through March 31, 2026. Prior to
April 1, 2021, the Company had a tax exemption on income arising from qualifying activities in Singapore based upon the achievement of certain contractual milestones, which the Company met as of December 31, 2020 and maintained through March 2021. The effect of applying these concessionary income tax rates rather than the statutory tax rate to income arising from qualifying activities in Singapore increased the Company’s net income
by $20 million, $20 million and $21 million and increased the Company’s net income per diluted share by $0.33, $0.32 and $0.33 
for the years ended December 31, 2022, 2021 and 2020, respectively.
During 2022, the Company’s effective tax rate differed from the 21% U.S. statutory tax rate primarily due to the jurisdictional mix of earnings, a
n
$18 million provision related to the
GILTI tax, including the
 impact of capitalizing research and 
development expenditures pursuant to IRC Section 174, and a tax benefit of $
7 million on stock-based compensation.
The 2021 effective tax rate differed from the
21
% U.S. statutory tax rate primarily due to the jurisdictional mix of earnings, a $
10
 million provision related to the GILTI tax and a tax benefit of $
7
 million on stock-based compensation.
The 2020 effective tax rate differed from the 21% U.S. statutory tax rate primarily
due to the jurisdictional mix of earnings, an $
13
 million provision related to the GILTI tax and a tax benefit of $
7
 million on stock-based compensation.
At the end of 2018, and as a result of the enactment of the 2017 Act, we reevaluated our historic assertion and no longer considered undistributed earnings from foreign subsidiaries to be indefinitely reinvested. The Company recorded a tax provision of $
4
 million, $
4
 million and $
3
 million for 202
2
, 202
1
and 20
20
, respectively, for future withholding taxes and U.S. state taxes on the repatriation of 202
2
, 202
1
and 20
20
undistributed earnings.
 
 
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,
 
 
  
2022
 
 
2021
 
Deferred tax assets:
  
 
Net operating losses and credits
 
$
51,945    
$
55,813  
Depreciation
    18       —    
Operating leases
    19,771       19,288  
Amortization
    2,713       2,316  
Stock-based compensation
    7,947       8,074  
Deferred compensation
    23,488       30,105  
Deferred revenue
    13,555       10,997  
Revaluation of equity investments and licenses
    23       3,083  
Inventory
    6,463       5,405  
Accrued liabilities and reserves
    4,815       6,675  
Unrealized foreign currency gain/loss
    1,858       2,266  
Capitalized Section 174 Expenditures
    34,234       —    
Other
    1,098       6,713  
   
 
 
   
 
 
 
Total deferred tax assets
    167,928       150,735  
Valuation allowance
    (54,300     (58,834
   
 
 
   
 
 
 
Deferred tax assets, net of valuation allowance
    113,628       91,901  
Deferred tax liabilities:
               
Capitalized software
    (25,429     (24,357
Operating leases
    (19,543     (19,251
Indefinite-lived intangibles
    (16,057     (15,534
Depreciation
          (3,481
Deferred tax liability on foreign earnings
    (18,677     (17,283
   
 
 
   
 
 
 
Total deferred tax liabilities
    (79,706     (79,906
   
 
 
   
 
 
 
Net deferred tax assets
 
$

33,922    
$
11,995  
   
 
 
   
 
 
 
The Company has gross foreign net operating losses of $214 million, of which $188 million do not expire under current laws and $26
 million start expiring in 2023. As of December 31, 2022, the Company has provided a
deferred tax valuation allowance of $
54 million, of which $49 
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
$3 
million as of December 31, 2022, which represent the future tax benefit of foreign net operating loss carryforwards that do not expire under current law.
The Company accounts for its uncertain tax return 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 Company continues to classify interest and penalties related to unrecognized tax benefits as a component of the provision for income taxes.
 
 
 
  
2022
 
 
2021
 
 
2020
 
Balance at the beginning of the period
 
$

28,692     $ 28,666     $ 27,790  
Net reductions for settlement of tax audits
          (1,300     (399
Net reductions for lapse of statutes taken during the period
    (818     (433     (684
Net additions for tax positions taken during the current period
    1,145       1,759       1,959  
   
 
 
   
 
 
   
 
 
 
Balance at the end of the period
 
$
29,019     $ 28,692     $ 28,666  
   
 
 
   
 
 
   
 
 
 
As of 2022, the total amount of gross unrecognized tax benefits was $29 million, all of which, if recognized, would impact the Company’s effective tax rate.
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, 2017. 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.
As of December 31, 2022, the Company expects to record additional reductions in the measurement of its unrecognized tax benefits and related net interest and penalties of approximately $
18
 million within the next twelve months due to potential tax audit settlements and 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.
As of December 31, 2022, the Company is currently under an income tax audit in the U.S. for its 2017 and 2018 tax years. The Company is also subject to various foreign audits and inquiries and we currently do not expect any material adjustments.
The following is a summary of the activity of the Company’s valuation allowance for the years ended December 31, 2022, 2021 and 2020 (in thousands):
 
 
  
Balance at
Beginning
of Period
 
  
Charged to
Provision for
Income Taxes*
 
 
Other**
 
 
Balance at
End of
Period
 
Valuation allowance for deferred tax assets:
                                   
2022
   $ 58,834      $ (1,647    $ (2,887 )    $ 54,300  
2021
   $ 60,101      $ 2,919      $ (4,186    $ 58,834  
2020
   $ 51,221      $ 1,137      $ 7,743      $ 60,101  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 

 
*
These amounts have been recorded as part of the income statement provision for income taxes. The income statement effects of these amounts have largely been offset by amounts related to changes in other deferred tax balance sheet accounts. 
**
The changes in the valuation allowance during the years ended December 31, 2022 and 2021 are primarily due to the effect of foreign currency translation on a valuation allowance related to a net operating loss carryforward. The change in the valuation allowance during the year ended December 31, 2020 was primarily due to the effect of foreign currency translation on a valuation allowance related to a net operating loss carryforward and acquired historical net operating losses.
In March 2020, the U.S. federal government enacted the Coronavirus Aid, Relief and Economic Security Act (the “CARES Act”). The CARES Act is an emergency economic stimulus package in response to the
COVID-19
outbreak which, among other things, contains numerous income tax provisions. The CARES Act does not have a material impact on the Company’s consolidated financial statements or related disclosures.