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Income Taxes (Tables)

12 Months Ended

Dec. 31, 2020

Income Tax Disclosure [Abstract]

Income (Loss) Before Income Taxes And Minority Interests

The Company's geographic sources of income (loss) before income taxes and non-controlling interest are as follows (in millions):

			Year ended December 31,
			2020						2019						2018
United States			$	(181.2)					$	(308.2)					$	(181.8)
Foreign			357.8						584.8						936.8
Income before income taxes			$	176.6					$	276.6					$	755.0

Provision (Benefit) For Income Taxes

The Company's provision (benefit) for income taxes is as follows (in millions):

			Year ended December 31,
			2020						2019						2018
Current:
Federal			$	0.6					$	1.2					$	(2.0)
State and local			0.1						—						(2.2)
Foreign			54.0						48.5						55.3
			54.7						49.7						51.1
Deferred:
Federal			(69.2)						(5.0)						99.4
State and local			(66.4)						—						—
Foreign			21.1						18.0						(25.4)
			(114.5)						13.0						74.0
Total provision (benefit)			$	(59.8)					$	62.7					$	125.1

Reconciliation Of The U.S. Federal Statutory Income Tax Rate

A reconciliation of the U.S. federal statutory income tax rate to the Company's effective income tax rate is as follows:

						Year ended December 31,
						2020						2019						2018
U.S. federal statutory rate						21.0		%				21.0		%				21.0		%
Increase (decrease) resulting from:
State and local taxes, net of federal tax benefit						(1.4)						(2.6)						(1.0)
Impact of U.S. Tax Reform and related effects (1)						—						—						4.7
Impact of foreign operations						7.6						3.8						(1.2)
Impact of U.S. tax method changes (2)						—						—						(6.4)
Impact of the Domestication (3)						(35.7)						—						—
Change in valuation allowance and related effects (4)						(24.4)						1.8						0.6
Non-deductible share-based compensation costs						1.7						(0.5)						(0.5)
U.S. federal R&D credit						(3.6)						(3.7)						(1.1)
Nondeductible officer compensation						1.1						1.5						0.4
Other						(0.1)						1.4						0.1
Total						(33.8)		%				22.7		%				16.6		%

(1)For the year ended December 31, 2018, this primarily included expense of (i) $31.8 million, or 4.2%, related to the recognition of deferred tax liability for undistributed prior years' earnings of the foreign subsidiaries, (ii) $1.8 million, or 0.3% related to the limitation on deductibility of prior years’ executive compensation, and (iii) $1.5 million, or 0.2% related to the impact of the mandatory repatriation tax. These adjustments were made pursuant to SAB 118.

(2)For the year ended December 31, 2018, this included a one-time benefit of $48.2 million, or 6.4%, related to U.S. tax method changes made during the year that impacted the Company’s GILTI inclusion.

(3)On July 6, 2020, the Company completed a simplification of its corporate structure by repatriating the economic rights of its non-U.S. IP to the United States via domestication of certain foreign subsidiaries (the "Domestication"). The Domestication more closely aligns the Company's corporate structure with its operating structure in accordance with the OECD’s BEPS conclusions and changes to U.S. and European tax laws. The impact of the Domestication, which is regarded as a change in tax status, resulted in a benefit primarily from recognizing certain deferred tax assets, net of deferred tax liabilities, of $63.0 million, or 35.7%.

(4)For the year ended December 31, 2020, this included a benefit of $49.4 million, or 28.0%, for the release of a partial state valuation allowance due to an increase to forecasted domestic income as a result of the Domestication of certain foreign subsidiaries and an expense of $61.8 million, or 35.0%, primarily related to the expiration of Japan net operating losses, netted with the offsetting benefit of $61.8 million, or 35.0%, primarily for the decrease in the related valuation allowance for those same Japan net operating losses. For the year ended December 31, 2019, this included an expense of $11.2 million, or 4.0%, primarily related to the write-off of Hong Kong NOL and expiration of Japan NOL, netted with the offsetting benefit of $11.2 million, or 4.0%, primarily for the decrease in related valuation allowance for those same Hong Kong and Japan NOLs. For the year ended December 31, 2018, this included an expense of $135.2 million, or 17.9%, primarily related to the expiration of Japan NOLs, netted with the offsetting benefit of $135.2 million, or 17.9%, primarily for the decrease in the related valuation allowance for those same Japan NOLs.

Tax Effects Of Temporary Differences

The tax effects of temporary differences in the recognition of income and expense for tax and financial reporting purposes that give rise to significant portions of the net deferred tax asset (liability) are as follows (in millions):

						As of December 31,
						2020						2019
NOL and tax credit carryforwards						$	471.6					$	612.9
163 (j) interest expense carryforward						65.7						49.3
Lease liabilities (1)						32.5						22.1
ROU asset (1)						(32.5)						(22.1)
Tax-deductible goodwill and amortizable intangibles						(38.0)						(48.6)
Capitalization of research and development expenses						90.7						42.7
Reserves and accruals						68.4						27.5
Property, plant and equipment						(95.8)						(81.2)
Inventories						84.3						22.0
Undistributed earnings of foreign subsidiaries						(57.5)						(63.7)
Share-based compensation						7.7						10.3
Pension						21.2						26.3
Other						3.2						8.0
Deferred tax assets and liabilities before valuation allowance						621.5						605.5
Valuation allowance						(249.9)						(357.9)
Net deferred tax asset						$	371.6					$	247.6

(1)The deferred tax assets and liabilities disclosure as of December 31, 2019 has been adjusted to reflect the gross deferred tax right-of-use asset and related gross deferred lease liability recognized in accordance with the New Leasing Standard.

Activity For Unrecognized Gross Tax Benefits

The activity for unrecognized gross tax benefits is as follows (in millions):

			2020						2019						2018
Balance at beginning of year			$	130.0					$	112.2					$	114.8
Acquired balances			—						15.5						—
Additions for tax benefits related to the current year			11.9						9.4						7.4
Additions for tax benefits of prior years			12.3						8.0						2.8
Reductions for tax benefits of prior years			(1.4)						(0.2)						(1.9)
Lapse of statute			(1.3)						(8.2)						(10.9)
Settlements			(0.5)						(6.7)						—
Balance at end of year			$	151.0					$	130.0					$	112.2

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Tabular disclosure of the components of income tax expense attributable to continuing operations for each year presented including, but not limited to: current tax expense (benefit), deferred tax expense (benefit), investment tax credits, government grants, the benefits of operating loss carryforwards, tax expense that results from allocating certain tax benefits either directly to contributed capital or to reduce goodwill or other noncurrent intangible assets of an acquired entity, adjustments of a deferred tax liability or asset for enacted changes in tax laws or rates or a change in the tax status of the entity, and adjustments of the beginning-of-the-year balances of a valuation allowance because of a change in circumstances that causes a change in judgment about the realizability of the related deferred tax asset in future years.

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Tabular disclosure of the components of net deferred tax asset or liability recognized in an entity's statement of financial position, including the following: the total of all deferred tax liabilities, the total of all deferred tax assets, the total valuation allowance recognized for deferred tax assets.

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Tabular disclosure of the reconciliation using percentage or dollar amounts of the reported amount of income tax expense attributable to continuing operations for the year to the amount of income tax expense that would result from applying domestic federal statutory tax rates to pretax income from continuing operations.

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Tabular disclosure for tax positions taken in the tax returns filed or to be filed for which it is more likely than not that the tax position will not be sustained upon examination by taxing authorities and other income tax contingencies. Includes, but is not limited to, interest and penalties, reconciliation of unrecognized tax benefits, unrecognized tax benefits that would affect the effective tax rate, tax years that remain subject to examination by tax jurisdictions, and information about positions for which it is reasonably possible that amounts unrecognized will significantly change within 12 months.

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