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Income Taxes | 12 Months Ended
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Dec. 31, 2023
Income Tax Disclosure [Abstract] |
Income Taxes | Income before income taxes for the years ended December 31, 2023, 2022 and 2021 was derived from the following sources:
(In thousands) | 2023 |  | 2022 |  | 2021
Domestic | $ | (457,888) |  |  | $ | (272,365) |  |  | $ | 137,145 |
Foreign | 630,558 |  |  | 519,445 |  |  | 341,931 |
Income before income tax expense | $ | 172,670 |  |  | $ | 247,080 |  |  | $ | 479,076 |
Income tax (benefit) expense for the years ended December 31, 2023, 2022 and 2021 is summarized as follows:
(In thousands) | 2023 |  | 2022 |  | 2021
Current: |  |  |  |  |
Federal | $ | 10,835 |  |  | $ | 39,216 |  |  | $ | 9,187 |
State | 1,267 |  |  | 4,077 |  |  | 2,939 |
Foreign | 125,091 |  |  | 97,611 |  |  | 76,257 |
| 137,193 |  |  | 140,904 |  |  | 88,383 |
Deferred (net of valuation allowance): |  |  |  |  |
Federal | (135,408) |  |  | (90,238) |  |  | (11,726) |
State | (5,829) |  |  | (5,749) |  |  | (498) |
Foreign | (4,369) |  |  | (6,757) |  |  | (6,209) |
| (145,606) |  |  | (102,744) |  |  | (18,433) |
Income tax (benefit) expense | $ | (8,413) |  |  | $ | 38,160 |  |  | $ | 69,950 |
Income tax (benefit) expense differs from the expected amounts based upon the statutory federal tax rates for the years ended December 31, 2023, 2022 and 2021 as follows:
(In thousands) | 2023 |  | 2022 |  | 2021
Expected federal income tax at statutory rate | $ | 36,261 |  |  | $ | 51,887 |  |  | $ | 100,606 |
State income taxes before valuation allowance, net of federal tax effect | (9,374) |  |  | (5,907) |  |  | (1,333) |
Effect of foreign source income | (18,383) |  |  | (7,607) |  |  | (15,862) |
Tax contingencies | 11,048 |  |  | 5,762 |  |  | 4,696 |
Valuation allowance | 9,032 |  |  | 8,052 |  |  | 9,984 |
U.S. federal research credit | (18,679) |  |  | (13,525) |  |  | (8,469) |
Equity compensation | 7,431 |  |  | 5,290 |  |  | (8,899) |
Foreign derived intangible income | (5,144) |  |  | (15,265) |  |  | (6,496) |
Legal entity restructuring capital loss | — |  |  | — |  |  | (5,079) |
Acquisition related retention, severance, and transaction costs | — |  |  | 8,924 |  |  | — |
Legal entity divestiture activity | (20,311) |  |  | — |  |  | — |
Other items, net | (294) |  |  | 549 |  |  | 802 |
Income tax (benefit) expense | $ | (8,413) |  |  | $ | 38,160 |  |  | $ | 69,950 |
The Company has made employment and spending commitments to Singapore. In return for those commitments, the Company was granted a partial tax holiday for eight years starting in 2013. During 2017, this agreement was extended to 2027 in exchange for revised employment and spending commitments. The income tax benefits attributable to the tax status are $19.7 million ($0.13 per diluted share), $24.8 million ($0.17 per diluted share) and $13.9 million ($0.10 per diluted share) for the years ending December 31, 2023, 2022 and 2021, respectively. The 2023, 2022 and 2021 effective tax rates include additional benefits of $12.1 million, $14.2 million and $8 million because the corporate tax rate in Singapore is lower than the U.S. rate. At December 31, 2023, there were approximately $136.0 million of accumulated undistributed earnings of subsidiaries outside of the United States, all of which are considered to be indefinitely reinvested. Management estimates that approximately $16.1 million of withholding taxes would be incurred if these undistributed earnings were distributed. The significant components of the Company’s deferred tax assets and deferred tax liabilities at December 31, 2023 and 2022 are as follows:
(In thousands) | 2023 |  | 2022
Deferred tax assets attributable to: |  |  |
Accounts receivable | $ | 1,304 |  |  | $ | 1,239 |
Inventory | 12,456 |  |  | 14,862 |
Accruals not currently deductible for tax purposes | 16,341 |  |  | 25,787 |
Net operating loss and credit carryforwards | 55,685 |  |  | 57,760 |
Capital loss carryforward | 5,281 |  |  | 895 |
Equity compensation | 11,382 |  |  | 15,249 |
Interest expense limitations | 37,691 |  |  | 8,067 |
Capitalization of ER&D expense | 100,832 |  |  | 53,179 |
Other, net | 15,064 |  |  | — |
Gross deferred tax assets | 256,036 |  |  | 177,038 |
Valuation allowance | (60,330) |  |  | (48,047) |
Total deferred tax assets | 195,706 |  |  | 128,991 |
Deferred tax liabilities attributable to: |  |  |
Purchased intangible assets | (230,550) |  |  | (364,979) |
Other, net | — |  |  | (2,397) |
Depreciation and Amortization | (44,007) |  |  | (55,898) |
Total deferred tax liabilities | (274,557) |  |  | (423,274) |
Net deferred tax liabilities | $ | (78,851) |  |  | $ | (294,283) |
Deferred tax assets are generally required to be reduced by a valuation allowance if it is more likely than not that some portion or all of the deferred tax assets will not be realized. As of December 31, 2023 and 2022, the Company had net U.S. deferred tax liabilities of $76.7 million and deferred tax assets of $298.5 million, respectively, which are composed of temporary differences and various tax credit carryforwards. The Company had state operating loss and credit carryforwards of approximately $23.3 million, which begin to expire in 2024. Management believes that it is more likely than not that the benefit from certain state net operating loss carryforwards, state credit carryforwards, capital loss carryforwards and certain federal foreign tax credit carryforwards will not be realized. In recognition of this risk, management has provided valuation allowances of $29.7 million and $18.5 million as of December 31, 2023 and 2022, respectively, on the related deferred tax assets. If the assumptions change and management determines the assets will be realized, the tax benefits relating to any reversal of the valuation allowance on deferred tax assets at December 31, 2023 will be recognized as a reduction of income tax expense. As of December 31, 2023 and 2022, the Company had net non-U.S. deferred tax assets of $58.2 million and $52.3 million, respectively, for which management determined based upon the available evidence a valuation allowance of $30.6 million and $29.5 million as of December 31, 2023 and 2022, respectively, was required against the non-U.S. gross deferred tax assets. For other non-U.S. jurisdictions, management relies upon projections of future taxable income to utilize deferred tax assets. At December 31, 2023, the Company had foreign operating loss carryforwards of $60.8 million, which begin to expire in 2024. Benefits from tax positions should be recognized in the financial statements only when it is more likely than not that the tax positions will be sustained upon examination by the appropriate taxing authority that would have full knowledge of all relevant information. A tax position that meets the more-likely-than-not recognition threshold is measured at the largest amount of benefit that is greater than fifty percent likely of being realized upon ultimate settlement. Tax positions that fail to meet the more-likely-than-not recognition threshold should be recognized in the first subsequent financial reporting period in which that threshold is met. Previously recognized tax positions that no longer meet the more-likely-than-not recognition threshold should be derecognized in the first subsequent financial reporting period in which that threshold is no longer met. The provisions also provide guidance on the accounting for and disclosure of unrecognized tax benefits, interest and penalties. Reconciliations of the beginning and ending balances of the total amounts of gross unrecognized tax benefits for the years ended December 31, 2023 and 2022 are as follows:
(In thousands) | 2023 |  | 2022
Gross unrecognized tax benefits at beginning of year | $ | 53,478 |  |  | $ | 23,789 |
Increase from acquisition | — |  |  | 24,452 |
Increase in tax positions from prior years | 242 |  |  | 175 |
Decrease in tax positions from prior years | — |  |  | (248) |
Increases in tax positions for current year | 17,111 |  |  | 13,577 |
Settlement of tax positions for current year | — |  |  | (6,395) |
Lapse in statute of limitations | (3,114) |  |  | (1,872) |
Gross unrecognized tax benefits at end of year | $ | 67,717 |  |  | $ | 53,478 |
The total amount of net unrecognized tax benefits that, if recognized, would affect the effective tax rate was $53.4 million at December 31, 2023. Penalties and interest paid or received are recorded in other income, net in the consolidated statements of operations. As of December 31, 2023 and 2022, the Company had accrued interest and penalties related to unrecognized tax benefits of $6.6 million and $4.2 million, respectively. Expenses of $2.5 million, $2.0 million and $1.0 million were recognized as interest and penalties in the consolidated statements of operations for the years ended December 31, 2023, 2022 and 2021, respectively. The Company files income tax returns in the U.S. and in various state, local and foreign jurisdictions. The statutes of limitations related to both the consolidated federal income tax return and state returns are closed for all years up to and including 2019 and 2019, respectively. With respect to foreign jurisdictions, the statute of limitations varies from country to country, with the earliest open year for the Company’s major foreign subsidiaries being 2017. Due to the expiration of various statutes of limitations and settlements of audits, it is reasonably possible that the Company’s gross unrecognized tax benefit balance may decrease within the next twelve months by approximately $1.9 million. The Organization Economic Co-operation and Development (“OECD”) introduced Base Erosion and Profit Shifting (“BEPS”) Pillar 2 rules that impose a global minimum tax rate of 15%. Numerous countries, including European Union member states, have enacted or are expected to enact legislation to be effective as early as January 1, 2024, with general implementation of a global minimum tax by January 1, 2025. We are currently evaluating the potential impact on our consolidated financial statements and related disclosures.

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