Income Taxes

Earnings before income taxes for the years ended December 31, 2017, 2016 and 2015 consisted of the following components (in thousands):



	2017		2016		2015
United States	$	783,654	$	721,000	$	710,614
Other	251,069		219,652		291,731
	$	1,034,723	$	940,652	$	1,002,345

Components of income tax expense for the years ended December 31, 2017, 2016 and 2015 were as follows (in thousands):



	2017			2016			2015
Current:
Federal	$	316,031		$	239,217		$	229,224
State	29,768			21,779			22,041
Foreign	89,894			54,937			71,507
Deferred:
Federal	(358,300		)	(26,760		)	6,710
State	(3,670		)	189			(16,844		)
Foreign	(10,772		)	(7,355		)	(6,360		)
	$	62,951		$	282,007		$	306,278

Reconciliations between the statutory federal income tax rate and the effective income tax rate for the years ended December 31, 2017, 2016 and 2015 were as follows:



	2017		2016		2015
Federal statutory rate	35.0	%	35.0	%	35.0	%
Foreign rate differential	(2.6	)	(3.2	)	(3.3	)
R&D tax credits	(0.8	)	(0.7	)	(0.5	)
State taxes, net of federal benefit	1.9		1.9		2.0
Section 199 deduction	(1.3	)	(1.5	)	(1.3	)
Stock-based compensation	(3.9	)	(1.6	)	—
Tax Cuts and Jobs Act of 2017	(20.8	)	—		—
Other, net	(1.4	)	0.1		(1.3	)
	6.1	%	30.0	%	30.6	%

The deferred income tax balance sheet accounts arise from temporary differences between the amount of assets and liabilities recognized for financial reporting and tax purposes.

Components of the deferred tax assets and liabilities at December 31 were as follows (in thousands):



	2017			2016
Deferred tax assets:
Reserves and accrued expenses	$	121,509		$	186,120
Inventories	5,094			8,967
Net operating loss carryforwards	71,774			87,010
R&D credits	9,570			7,933
Foreign tax credits	—			9,203
Valuation allowance	(25,690		)	(26,009		)
Total deferred tax assets	$	182,257		$	273,224
Deferred tax liabilities:
Reserves and accrued expenses	$	39,566		$	13,915
Amortizable intangible assets	935,874			1,400,792
Plant and equipment	5,748			6,102
Total deferred tax liabilities	$	981,188		$	1,420,809

As of December 31, 2017, the Company had approximately $29.2 million of tax-effected U.S. federal net operating loss carryforwards that if not utilized will expire in years 2021 through 2037. The U.S. federal net operating loss carryforwards decreased from 2016 to 2017 primarily due to reduction in U.S. federal corporate tax rate for tax years beginning after December 31, 2017. The Company has approximately $26.1 million of tax-effected state net operating loss carryforwards (without regard to federal benefit of state) that if not utilized will expire in years 2018 through 2037. The state net operating loss carryforwards are primarily related to Florida and New Jersey, but the Company has smaller net operating losses in various other states. The Company has approximately $22.0 million of tax-effected foreign net operating loss carryforwards. Some of these net operating loss carryforwards have an indefinite carryforward period and those that do not if not utilized will begin to expire in 2018. Additionally, the Company has $11.3 million of U.S. federal and state research and development tax credit carryforwards (without regard to federal benefit of state) that will expire in years 2018 through 2037.

As of December 31, 2017, the Company determined that a total valuation allowance of $25.7 million was necessary to reduce U.S. federal and state deferred tax assets by $9.5 million and foreign deferred tax assets by $16.2 million, where it was more likely than not that all of such deferred tax assets will not be realized. As of December 31, 2017, based on the Company's estimates of future taxable income and any applicable tax-planning strategies within various tax jurisdictions, the Company believes that it is more likely than not that the remaining net deferred tax assets will be realized.

The Company recognizes in the consolidated financial statements only those tax positions determined to be "more likely than not" of being sustained upon examination based on the technical merits of the positions. A reconciliation of the beginning and ending amount of unrecognized tax benefits is as follows (in thousands):



	2017			2016			2015
Beginning balance	$	38,678		$	26,140		$	28,567
Additions for tax positions of prior periods	24,804			3,450			3,525
Additions for tax positions of the current period	4,174			9,012			3,299
Additions due to acquisitions	—			5,049			6,177
Reductions for tax positions of prior periods	(11,162		)	(1,165		)	(12,206		)
Reductions attributable to settlements with taxing authorities	(1,536		)	(568		)	(142		)
Reductions attributable to lapses of applicable statute of limitations	(2,769		)	(3,240		)	(3,080		)
Ending balance	$	52,189		$	38,678		$	26,140

The total amount of unrecognized tax benefits that, if recognized, would affect the effective tax rate is $50.4 million. Interest and penalties related to unrecognized tax benefits are classified as a component of income tax expense and totaled an expense of $1.3 million in 2017. Accrued interest and penalties were $5.1 million at December 31, 2017 and $3.8 million at December 31, 2016. During the next twelve months, it is reasonably possible that the unrecognized tax benefits may decrease by a net $2.3 million, mainly due to anticipated statute of limitations lapses in various jurisdictions.

The Company and its subsidiaries are subject to U.S. federal income tax as well as income tax in multiple state, city and foreign jurisdictions. The Company's federal income tax returns for 2015 through the current period remain subject to examination and the relevant state, city and foreign statutes vary. The Company does not expect the assessment of any significant additional tax in excess of amounts reserved.

The Tax Act was signed into U.S. law on December 22, 2017, which was prior to the end of the Company’s 2017 reporting period. The Tax Act contains provisions which impact the Company’s current and future income taxes including a reduction in the US federal corporate income tax rate from 35% to 21%, a one-time deemed mandatory repatriation tax imposed on all undistributed foreign earnings, and the introduction of a modified territorial taxation system.

The SEC released Staff Accounting Bulletin No. 118 (“SAB 118”) on December 22, 2017 to provide guidance where the accounting under ASC 740, Income Taxes, is incomplete for certain income tax effects of the Tax Act upon issuance of financial statements for the reporting period in which the Tax Act was enacted. SAB 118 provides that if a Company can determine a reasonable estimate, it should be reported as a provisional amount and adjusted during a measurement period. If a Company is unable to determine a reasonable estimate, no related provisional amounts would be recorded until a reasonable estimate can be determined, within the measurement period. The measurement period extends until all necessary information has been obtained, prepared, and analyzed, but no longer than 12-months from the date of enactment of the Tax Act.

The reduction in the US federal corporate income tax rate from 35% to 21% and certain immaterial changes in tax basis resulted in a one-time estimated benefit of $379.0 million due to remeasurement of the Company’s deferred taxes. This estimate is a provisional amount that will be finalized during the measurement period once all information pertaining to the deferred tax assets and liabilities has been obtained and analyzed. The reduction in tax rate will also impact the Company’s current tax expense in future periods beginning in 2018.

The one-time deemed mandatory repatriation tax on all undistributed foreign earnings resulted in a one-time estimated charge of $110.7 million. The Company will elect to pay the liability over 8 years. This federal and state tax estimate is a provisional amount that will be finalized during the measurement period once all information pertaining to the historical foreign earnings and profits with available tax credits has been obtained and analyzed.

The introduction of a modified territorial taxation system resulted in a one-time estimated charge of $28.7 million due to the Company’s change in its indefinite reinvestment assertion on foreign earnings. The Company now intends to distribute all historical earnings subject to the deemed repatriation tax and has provided for deferred taxes related to the future state and foreign tax cost to repatriate. This estimate is a provisional amount that will be finalized during the measurement period once all information pertaining to the underlying calculation has been obtained and analyzed, and interpretations to the legislation have been decided. The Company also incurred a one-time estimated charge of $24.2 million resulting from the write-off of indirect benefits associated with uncertain tax positions. The Company is currently unable to estimate the amount of these indirect benefits which will be utilizable due to uncertainty surrounding interpretations to the legislations and timing of the related tax payments. This amount will be finalized during the measurement period as information becomes available.

In January 2018, the FASB released guidance on accounting for taxes on the global intangible low-taxed income (“GILTI”) provisions of the Tax Act. The Company is still evaluating its position whether to account for deferred taxes related to GILTI inclusions or to treat any taxes on GILTI inclusions as a period cost. The Company will perform an analysis during the measurement period and will disclose the policy election in its financial statements once its analysis has been finalized.