Income Taxes

The income tax provision (benefit) was as follows:



(In millions)	2015			2014			2013
Continuing operations:
Current:
Federal	$	(60.7	)	$	(47.9	)	$	(127.5	)
State	(0.4		)	(4.0		)	(10.2		)
Foreign	9.4			9.8			7.9
Total	(51.7		)	(42.1		)	(129.8		)
Deferred:
Federal	(90.9		)	34.1			62.7
State	30.4			(0.2		)	4.6
Foreign	0.1			(0.5		)	(1.1		)
Total	(60.4		)	33.4			66.2
Income tax benefit from continuing operations	$	(112.1	)	$	(8.7	)	$	(63.6	)
Income tax provision (benefit) from discontinued operations	$	—		$	(0.3	)	$	161.4
Total company income tax provision (benefit)	$	(112.1	)	$	(9.0	)	$	97.8

The following is a reconciliation of income taxes computed at the statutory U.S. Federal income tax rate to the actual effective income tax benefit from continuing operations:



	Income Tax Provision (Benefit)
(In millions)	2015			2014			2013
Taxes computed at the federal rate	$	(167.3	)	$	0.5		$	(54.2	)
State and local income taxes, net of federal tax benefit	(20.6		)	(2.0		)	(11.8		)
Tax reserve adjustments	3.9			(0.5		)	(10.2		)
Repatriation of foreign earnings	13.4			0.3			9.4
Valuation allowance	74.5			0.5			9.1
Adjustment to prior years’ taxes	(5.4		)	0.1			(5.3		)
Foreign earnings taxed at different rate	(11.2		)	(6.6		)	(2.5		)
Other	0.6			(1.0		)	1.9
Income tax benefit	$	(112.1	)	$	(8.7	)	$	(63.6	)

In 2015, the Company’s results reflected a three year cumulative loss from U.S. operations; prior thereto, the Company’s historical results reflected a three year cumulative profit. The three year cumulative loss limits the ability to consider other positive subjective evidence, such as projections of future results, to assess the realizability of deferred tax assets. As a result of this assessment, the Company established a $68.4 million valuation allowance in 2015, including $49.3 million for certain state and federal tax benefits recognized in prior years, and a $19.1 million valuation allowance recorded as part of the current year’s effective tax rate, representing approximately a 4% tax rate impact. Other valuation allowances recognized in 2015 and prior years relate to uncertainties of realizing tax attributes unrelated to the U.S. operations cumulative loss impact.

In general, the Company is responsible for filing consolidated U.S. Federal, foreign and combined, unitary or separate state income tax returns. The Company is responsible for paying the taxes relating to such returns, including any subsequent adjustments resulting from the redetermination of such tax liability by the applicable taxing authorities. No provision has been made for U.S. Federal, state or additional foreign taxes related to approximately $168 million of undistributed earnings of foreign subsidiaries which have been permanently re-invested. It is not practical to determine the deferred tax liability on these earnings.

Income (loss) from continuing operations before income taxes for the Company’s U.S. and non-U.S. operations was as follows:



(In millions)	2015			2014			2013
U.S.	$	(534.6	)	$	(46.1	)	$	(180.0	)
Non-U.S.	56.6			47.6			25.2
Income (loss) from continuing operations before income taxes	$	(478.0	)	$	1.5		$	(154.8	)

Income taxes paid and amounts received as refunds were as follows:



(In millions)	2015			2014			2013
Income taxes paid	$	10.8		$	15.1		$	21.4
Income tax refunds received	(63.3		)	(20.2		)	(18.3		)
Income taxes paid (received), net	$	(52.5	)	$	(5.1	)	$	3.1

The Company’s income tax payments have benefited over the last several years from provisions under the U.S. tax code allowing companies to immediately deduct a significant portion of the cost of new capital investments placed into service. In 2015, the Company received a $59.9 million federal tax refund of prior years’ taxes paid. After this refund, the Company has approximately $166 million of tax-effected federal net operating loss carryforwards and $43 million of other federal tax credits to offset future federal tax liabilities.

Deferred income taxes result from temporary differences in the recognition of income and expense for financial and income tax reporting purposes, and differences between the fair value of assets acquired in business combinations accounted for as purchases for financial reporting purposes and their corresponding tax bases. Deferred income taxes represent future tax benefits or costs to be recognized when those temporary differences reverse. The categories of assets and liabilities that have resulted in differences in the timing of the recognition of income and expense at December 31, 2015 and 2014 were as follows:



(In millions)	2015			2014
Deferred income tax assets
Pensions	$	281.0		$	251.8
Postretirement benefits other than pensions	144.7			169.0
Federal and state net operating loss tax carryovers	228.1			122.7
Federal and state tax credits	52.2			53.6
Deferred compensation and other benefit plans	25.9			25.6
Self insurance reserves	10.8			10.1
Other items	85.2			79.1
Gross deferred income tax assets	827.9			711.9
Valuation allowance for deferred tax assets	(105.1		)	(34.4		)
Total deferred income tax assets	722.8			677.5
Deferred income tax liabilities
Bases of property, plant and equipment	664.1			579.5
Inventory valuation	62.2			111.7
Bases of amortizable intangible assets	25.4			75.5
Other items	46.7			53.9
Total deferred tax liabilities	798.4			820.6
Net deferred tax liability	$	(75.6	)	$	(143.1	)

The Company had $105.1 million and $34.4 million in deferred tax asset valuation allowances at December 31, 2015 and 2014, respectively. The valuation allowance at December 31, 2015 includes $24.8 million for federal foreign tax credits, $61.8 million for state net operating loss tax carryforwards, $1.4 million for foreign net operating losses and credits, $13.8 million for state tax credits and $3.3 million for state temporary differences, since the Company has concluded, based on current tax laws, that it is more likely than not that these tax benefits would not be realized. For the state net operating loss tax carryforwards, expiration will generally occur within 20 years of the year generated and some utilization of the tax benefit may be limited to $5 million per year or 30% of apportioned income, whichever is greater.

The changes in the liability for unrecognized income tax benefits for the years ended December 31, 2015, 2014 and 2013 were as follows:



(In millions)	2015			2014			2013
Balance at beginning of year	$	73.4		$	72.8		$	29.2
Increases in prior period tax positions	4.2			2.0			0.1
Decreases in prior period tax positions	(0.6		)	(0.6		)	(5.8		)
Increases in current period tax positions	1.3			0.7			60.4
Expiration of the statute of limitations	(0.7		)	(0.5		)	(0.7		)
Settlements	(62.1		)	(0.7		)	(8.6		)
Interest and penalties, net	(0.5		)	(0.3		)	(1.8		)
Balance at end of year	$	15.0		$	73.4		$	72.8

At December 31, 2015, interest and penalties included in the liability for unrecognized tax benefits were $3.9 million.

For the year ended December 31, 2014, $60.9 million of the liability for unrecognized income tax benefits relates to temporary differences, which would not impact the effective tax rate upon resolution of the uncertainty. In 2015, the Company resolved these various uncertain tax position matters related to temporary differences which resulted in this $60.9 million long-term liability for uncertain tax positions to be reclassified to a deferred tax liability. Including tax positions for which the Company determined that the tax position would not meet the more-likely-than-not recognition threshold upon examination by the tax authorities based upon the technical merits of the position, the total estimated unrecognized tax benefit that, if recognized, would affect ATI’s effective tax rate was approximately $12 million. At this time, the Company believes that it is reasonably possible that approximately $4 million of the estimated unrecognized tax benefits as of December 31, 2015 will be recognized within the next twelve months based on the expiration of statutory review periods.

The Company, and/or one of its subsidiaries, files income tax returns in the U.S. Federal jurisdiction and in various state and foreign jurisdictions. A summary of tax years that remain subject to examination, by major tax jurisdiction, is as follows:



Jurisdiction		Earliest Year Open to Examination
U.S. Federal		2014
States:
Alabama		2012
Illinois		2012
North Carolina		2010
Oregon		2012
Pennsylvania		2012
Foreign:
China		2011
Germany		2014
Poland		2011
United Kingdom		2012