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Income Taxes
9 Months Ended
Sep. 30, 2018
Income Tax Disclosure [Abstract]  
Income Taxes Income Taxes        
On December 22, 2017, the U.S. government enacted comprehensive tax legislation, commonly referred to as the Tax Cuts and Jobs Act (the “Tax Act”). The Tax Act made broad and complex changes to the U.S. tax code, including, among other things, reducing the U.S. federal corporate tax rate from 35% to 21%, requiring companies to pay a one-time transition tax on earnings from certain foreign subsidiaries and creating new taxes on certain foreign sourced earnings. The Company applied the guidance in Staff Accounting Bulletin 118 when accounting for the enactment date effects of the Tax Act, which allowed the Company to make provisional estimates at December 31, 2017.
As a result of the reduction of the U.S. corporate tax rate to 21%, U.S. generally accepted accounting principles required a re-measurement of our deferred tax assets and liabilities as of the date of enactment, with the resulting tax effects accounted for in the reporting period of enactment. Based on available information, the Company’s estimated value of its net deferred federal and state tax liability balances were reduced by approximately $39.3 million, which was recorded as a reduction of income tax
expense in the Company’s Consolidated Statements of Operations for the year ended December 31, 2017. During the third quarter of 2018, we completed the accounting for such revaluation and determined that no material adjustment was required.
The Tax Act provides for a change from a worldwide to a territorial tax system and requires a one-time transition tax on certain deferred foreign income of specified foreign corporations. The Company has concluded, after completion of its analysis that it is not subject to such transition tax.
Our income tax provision for the three and nine months ended September 30, 2018 included an estimate of the minimum tax on global intangible low-taxed income for certain earnings of our foreign subsidiaries, as required under the Tax Act. The Company has elected to recognize such tax as an expense in the period incurred. Additionally, during the third quarter of 2018, we completed our analysis of the effects of the Tax Act related to the repatriation of certain foreign earnings and have recognized a tax liability of approximately $0.1 million as a result of such evaluation.
For the three months ended September 30, 2018 and 2017, our income tax provision from continuing operations was $29.7 million and $38.6 million, respectively, based on an effective income tax rate, before discrete items and less amounts attributable to noncontrolling interests, of 27.7% and 37.1%, respectively. The actual income tax rate on income from continuing operations, less amounts attributable to noncontrolling interests, for the three months ended September 30, 2018 and 2017, inclusive of discrete items, was 27.1% and 37.3%, respectively. For the nine months ended September 30, 2018 and 2017, our income tax provision from continuing operations was $76.9 million and $98.5 million, respectively, based on an effective income tax rate, before discrete items and less amounts attributable to noncontrolling interests, of 27.7% and 37.4%, respectively. The actual income tax rate on income from continuing operations, less amounts attributable to noncontrolling interests, for the nine months ended September 30, 2018 and 2017, inclusive of discrete items, was 27.1% and 36.0%, respectively. The decrease in the 2018 income tax provision and the 2018 actual income tax rate on income from continuing operations was primarily due to the enactment of the Tax Act.
As of September 30, 2018 and December 31, 2017, the amount of unrecognized income tax benefits was $0.8 million.
We report interest expense and/or income related to unrecognized income tax benefits in the income tax provision. As of September 30, 2018 and December 31, 2017, we had approximately $0.1 million of accrued interest expense related to unrecognized income tax benefits included as a liability in the Condensed Consolidated Balance Sheets. Total income tax reserves included in “Other long-term liabilities” were $0.9 million as of September 30, 2018 and December 31, 2017. For the three months ended September 30, 2018 and 2017, less than $0.1 million of interest income and $0.1 million of interest expense, respectively, was recognized in the income tax provision. For the nine months ended September 30, 2018 and 2017, less than $0.1 million and $0.3 million of interest income, respectively, was recognized in the income tax provision.
We do not anticipate any significant changes to our reserves for uncertain tax positions in the next twelve months. We file income tax returns with the Internal Revenue Service and various state, local and foreign tax agencies. The Company is currently under examination by various taxing authorities for the years 2012 through 2016. During the first quarter of 2017, the Company settled an examination with a taxing authority which resulted in a $3.3 million reversal of reserves for previously uncertain tax positions.