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Income Taxes
 12 Months Ended
Dec. 31, 2021
Income Tax Disclosure [Abstract]  
Income Taxes INCOME TAXES
Income before provision for income taxes for the years ended December 31, 2021, 2020, and 2019, consisted of the following (in millions):
 Years Ended December 31,
 202120202019
U.S.$1,298.7 $926.8 $1,053.7 
Foreign591.6 280.2 448.5 
Total income before provision for income taxes$1,890.3 $1,207.0 $1,502.2 
The provision for income taxes for the years ended December 31, 2021, 2020, and 2019, consisted of the following (in millions):
 Years Ended December 31,
 202120202019
Current
Federal$158.8 $34.2 $82.0 
State17.3 21.5 26.5 
Foreign50.1 26.9 18.0 
226.2 82.6 126.5 
Deferred
Federal(21.4)23.8 8.5 
State0.5 1.6 3.2 
Foreign(43.1)32.2 (17.8)
(64.0)57.6 (6.1)
Total income tax expense$162.2 $140.2 $120.4 
Income tax expense differs from amounts computed by applying the statutory federal income rate of 21% for the years ended December 31, 2021, 2020, and 2019, as a result of the following (in millions):
 Years Ended December 31,
 202120202019
Federal tax at statutory rate$397.0 $253.5 $315.5 
Increase (reduction) in tax resulting from:
State taxes, net of federal benefits33.1 23.1 29.7 
Foreign rate differential(54.3)(19.3)(56.2)
U.S. tax on foreign earnings40.1 29.3 55.0 
Research and development credit(30.7)(37.1)(32.7)
Share-based compensation not benefited17.8 14.3 13.5 
Unrecognized tax benefit related to share-based compensation13.6 39.3 — 
Reversal of unrecognized tax benefits(3.0)(4.0)(8.4)
Excess tax benefits related to share-based compensation (185.8)(166.2)(146.5)
Deferred tax re-measurement(66.4)— (51.3)
Other0.8 7.3 1.8 
Total income tax expense$162.2 $140.2 $120.4 
Deferred income taxes reflect tax carry forwards and the net tax effects of temporary differences between the carrying amounts of assets and liabilities for financial reporting and the amounts used for income tax purposes. Significant components of the Company’s deferred tax assets and liabilities are as follows (in millions):
 December 31,
 20212020
Deferred tax assets:
Net operating losses$9.7 $27.7 
Share-based compensation expense110.9 101.1 
Lease liabilities15.2 12.0 
Expenses deducted in later years for tax purposes38.4 29.3 
Intangible assets373.9 321.8 
Research and other credits98.5 76.3 
Other5.3 — 
Gross deferred tax assets651.9 568.2 
Valuation allowance(104.6)(81.4)
Deferred tax assets547.3 486.8 
Deferred tax liabilities:
Property, plant, and equipment(79.4)(91.1)
Right-of-use assets(12.3)(8.4)
Intangible assets(9.7)(10.1)
Other(5.1)(13.2)
Deferred tax liabilities(106.5)(122.8)
Net deferred tax assets$440.8 $364.0 
As of December 31, 2021, and 2020, the Company had valuation allowances of $104.6 million and $81.4 million, respectively, primarily related to California research and development credit carry forwards, for which the Company does not believe a tax benefit is more likely than not to be realized.
As of December 31, 2021, the Company had US and foreign federal net operating loss carryforwards of $23.9 million and foreign local net operating loss carryforwards of $207.3 million, which will begin to expire in 2027, if not utilized. Utilization of these net operating loss carryforwards may be subject to certain limitations. The Company does not expect the limitations to result in any permanent loss of these tax benefits.
The Company intends to repatriate earnings from its Swiss subsidiary and joint venture in Hong Kong, as needed, and the U.S. and foreign tax implications of such repatriations are not expected to be significant. The Company will continue to indefinitely reinvest earnings from the rest of its foreign subsidiaries, which are not significant.
The Company’s 2021 income tax expense included a one-time benefit of $66.4 million from re-measurement of its Swiss deferred tax assets resulting from the extension of the economic useful life of certain intangible assets. The Company’s 2019 income tax expense included a one-time benefit of $51.3 million associated with re-measurement of its Swiss deferred tax assets due to a Swiss statutory tax rate increase enacted as part of Swiss tax reform in August 2019.
A reconciliation of the beginning and ending amounts of gross unrecognized income tax benefits for the years ended December 31, 2021, 2020, and 2019, are as follows (in millions):
 Years Ended December 31,
 202120202019
Beginning balance$176.3 $96.7 $78.8 
Increases related to tax positions taken during the current year40.6 40.1 26.5 
Increases related to tax positions taken during a prior year11.2 46.1 1.2 
Decreases related to tax positions taken during a prior year(1.3)— — 
Decreases related to settlements with tax authorities(0.2)(0.5)(3.8)
Decreases related to expiration of statute of limitations(4.1)(6.1)(6.0)
Ending balance$222.5 $176.3 $96.7 
As of December 31, 2021, 2020, and 2019, gross interest related to unrecognized tax benefits accrued was $14.9 million, $11.0 million, and $2.9 million, respectively. The Company’s net unrecognized tax benefits and related interest are presented in other long-term liabilities and long term deferred tax assets on the Consolidated Balance Sheets.
Total gross unrecognized tax benefits as of December 31, 2021, were $222.5 million, which, if recognized, would result in a reduction of the Company’s effective tax rate.
In July 2015, a U.S. Tax Court opinion (the “2015 Opinion”) was issued involving an independent third party related to charging foreign subsidiaries for share-based compensation. Based on the findings of the U.S. Tax Court, direct share-based compensation had been excluded from the Company’s intercompany charges starting in 2015. In June 2019, the Ninth Circuit Court of Appeals (the “Ninth Circuit”) reversed the 2015 Opinion (the “Ninth Circuit Opinion”). Subsequently, a re-hearing of the case was requested, but was denied in November 2019. In February 2020, a petition was filed to appeal the Ninth Circuit Opinion to the U.S. Supreme Court. The petition was denied by the U.S. Supreme Court on June 22, 2020, which makes the Ninth Circuit Opinion binding precedent in the Ninth Circuit. As a result, the Company recorded an increase in the income tax provision of $39.3 million during the year ended December 31, 2020. An additional charge of $13.6 million related to this matter was recorded to income tax expense in 2021, primarily as a result of additional IRS guidance issued in July 2021. The Company will continue to monitor future IRS actions or other developments regarding this matter and will assess the impact of any such developments to its income tax provision in the quarter that they occur. The Company is treating share-based compensation expense in accordance with the Ninth Circuit Opinion for 2020 and future periods.
The Company files federal, state, and foreign income tax returns in many U.S. and OUS jurisdictions. Years before 2016 are closed for the significant jurisdictions. Certain of the Company’s unrecognized tax benefits could change due to activities of various tax authorities, including potential assessment of additional tax, possible settlement of audits, or through normal expiration of various statutes of limitations, which could affect the Company’s effective tax rate in the period in which they change. Due to the uncertainty related to the timing and potential outcome of audits, the Company cannot estimate the range of reasonably possible change in unrecognized tax benefits that may occur in the next 12 months.
The Company is subject to the examination of its income tax returns by the Internal Revenue Service and other tax authorities. The outcome of these audits cannot be predicted with certainty. The Company’s management regularly assesses the likelihood of adverse outcomes resulting from these examinations to determine the adequacy of the Company’s provision for income taxes. If any issues addressed in the Company’s tax audits are resolved in a manner not consistent with management’s expectations, the Company could be required to adjust its provision for income taxes in the period such resolution occurs.