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Income Taxes
9 Months Ended
Jun. 30, 2017
Income Taxes  
Income Taxes

 

10.Income Taxes

 

The Company’s effective tax rate from continuing operations was 0.5% and (18.6)% for the nine months ended June 30, 2017 and 2016, respectively. The most significant items contributing to the difference between the statutory U.S. federal income tax rate of 35% and the Company’s effective tax rate for the nine month period ended June 30, 2017 were the recognition of a benefit of $57.2 million related to the release of valuation allowances in the United Kingdom, a benefit of $21.2 million due to a recapitalization of a European subsidiary (described further below), a benefit of $20.1 million related to non-controlling interests, a benefit of $14.5 million related to the effect of the favorable tax impacts of changes in the geographical mix of income, a benefit of $14.2 million related to income tax credits and incentives, partially offset by tax expense of $13.1 million related to non-deductible expenses. All of these factors are expected to have a continuing impact on the effective tax rate except for the impact of the release of valuation allowances in the United Kingdom and the benefit related to the recapitalization.

 

The Company’s effective tax rate from continuing operations was 8.2% and (71.2)% for the three months ended June 30, 2017 and 2016, respectively. The most significant items contributing to the difference between the statutory U.S. federal income tax rate of 35% and the Company’s effective tax rate for the three month period ended June 30, 2017 were a benefit of $21.2 million due to a recapitalization of a European subsidiary (described further below), a benefit of $12.1 million related to non-controlling interests, a benefit of $7.1 million related to the favorable tax impacts of changes in the geographical mix of income, and a benefit of $6.8 million related to income tax credits and incentives, partially offset by tax expense of $6.9 million related to non-deductible expenses.

 

In the third quarter of 2017, the Company recapitalized one of its European subsidiaries which resulted in the Company indefinitely reinvesting a portion of its non-U.S. undistributed earnings that U.S. tax had previously been provided for and released the associated $21.2 million deferred tax liability. These non-U.S. earnings are now intended to be reinvested indefinitely outside of the U.S to meet the Company’s current and future cash needs of its European operations.

 

Valuation allowances in the amount of $57.2 million in the United Kingdom were released due to sufficient positive evidence obtained during the second quarter of 2017. The Company evaluated the positive evidence against any negative evidence and determined that it is more likely than not that the deferred tax assets will be realized. This positive evidence includes an improvement in earnings, the use of net operating losses on a taxable basis, and better management of pension liabilities due to positive effects of pension asset management and stabilization of interest rates.

 

The Company is utilizing the annual effective tax rate method under ASC 740 to compute its interim tax provision. The Company’s effective tax rate fluctuates from quarter to quarter due to various factors including the change in the mix of global income and expenses, outcomes of administrative audits, changes in the assessment of valuation allowances due to management’s consideration of new positive or negative evidence during the quarter, and changes in enacted tax laws and their interpretations which upon enactment include possible tax reform contemplated in the United States and other jurisdictions could have a material impact on the Company’s income tax expense and deferred tax balances.

 

The Company believes the outcomes which are reasonably possible within the next twelve months, including lapses in statutes of limitations, will not result in a material change in the liability for uncertain tax positions.

 

Generally, the Company does not provide for U.S. taxes or foreign withholding taxes on gross book-tax differences in its non-U.S. subsidiaries because such basis differences of approximately $1.8 billion are able to and intended to be reinvested indefinitely. If these basis differences were distributed, foreign tax credits could become available under current law to partially or fully reduce the resulting U.S. income tax liability. There may also be additional U.S. or foreign income tax liability upon repatriation, although the calculation of such additional taxes is not practicable. The Company’s deferred tax liability related to certain foreign subsidiaries for which the undistributed earnings are not intended to be reinvested indefinitely was $92.0 million and $113.2 million for the periods ended June 30, 2017 and September 30, 2016, respectively.