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Income Taxes
12 Months Ended
Dec. 31, 2020
Income Tax Disclosure [Abstract]  
Income Taxes

15. Income Taxes

 

 

 

Year Ended December 31,

 

 

 

2020

 

 

2019

 

 

2018

 

 

 

(Dollars in millions)

 

Components of Earnings and Taxes from Operations

 

 

 

 

 

 

 

 

 

 

 

 

Income (Loss) Before Income Taxes:

 

 

 

 

 

 

 

 

 

 

 

 

U.S.

 

$

41.5

 

 

$

25.9

 

 

$

(71.4

)

International

 

 

(61.6

)

 

 

8.4

 

 

 

44.5

 

Total

 

$

(20.0

)

 

$

34.3

 

 

$

(26.9

)

Income Tax Expense (Benefit):

 

 

 

 

 

 

 

 

 

 

 

 

Current:

 

 

 

 

 

 

 

 

 

 

 

 

U.S.

 

$

(6.5

)

 

$

7.1

 

 

$

3.8

 

State and local

 

 

0.1

 

 

 

0.4

 

 

 

0.3

 

International

 

 

(2.6

)

 

 

17.5

 

 

 

20.4

 

Total current income tax expense

 

 

(9.0

)

 

 

25.0

 

 

 

24.5

 

Deferred:

 

 

 

 

 

 

 

 

 

 

 

 

U.S.

 

 

(1.1

)

 

 

(42.6

)

 

 

(14.1

)

State and local

 

 

0.1

 

 

 

(19.3

)

 

 

(2.2

)

International

 

 

(6.0

)

 

 

(7.5

)

 

 

0.2

 

Total deferred income tax benefit

 

 

(7.0

)

 

 

(69.4

)

 

 

(16.1

)

Total income tax (benefit) expense

 

$

(16.0

)

 

$

(44.4

)

 

$

8.4

 

 

 

 

 

 

Year Ended December 31,

 

 

 

2020

 

 

2019

 

 

2018

 

Effective Rate Reconciliation

 

 

 

 

 

 

 

 

 

 

 

 

U.S. statutory rate%

 

 

21.0

%

 

 

21.0

%

 

 

(21.0

)%

Change in valuation allowance

 

 

(0.3

)

 

 

(176.1

)

 

 

10.8

 

State income taxes, net of federal benefit

 

 

2.2

 

 

 

3.9

 

 

 

(31.2

)

Share-based compensation

 

 

3.9

 

 

 

(5.8

)

 

 

(10.0

)

International tax rate differential

 

 

8.9

 

 

 

3.8

 

 

 

13.4

 

Foreign dividend income

 

 

 

 

 

 

 

 

20.1

 

Foreign capital gain income

 

 

(7.5

)

 

 

3.2

 

 

 

7.1

 

Unremitted foreign earnings

 

 

14.5

 

 

 

(2.0

)

 

 

4.1

 

Global intangible low-taxed income

 

 

 

 

 

 

 

 

23.0

 

Base erosion tax

 

 

33.9

 

 

 

19.9

 

 

 

14.1

 

Reserve for tax contingencies

 

 

1.2

 

 

 

(0.3

)

 

 

0.4

 

Change in tax rate

 

 

 

 

 

(1.0

)

 

 

(5.9

)

Other

 

 

2.2

 

 

 

4.0

 

 

 

6.3

 

Income tax provision%

 

 

80.0

%

 

 

(129.4

)%

 

 

31.2

%

 

Our income tax provision represents federal, state, and international taxes on our income recognized for financial statement purposes and includes the effects of temporary differences between financial statement income and income recognized for tax return purposes. Deferred tax assets and liabilities are recorded for temporary differences between the financial reporting basis and the tax basis of assets and liabilities. We record a valuation allowance to reduce our deferred tax assets to reflect the net deferred tax assets that we believe will be realized. In assessing the likelihood that we will be able to recover our deferred tax assets and the need for a valuation allowance, we consider all available evidence, both positive and negative, including historical levels of pre-tax book income, expiration of net operating losses, changes in our debt and equity structure, expectations and risks associated with estimates of future taxable income, ongoing prudent and feasible tax planning strategies, as well as current tax laws. As of December 31, 2020, we continue to record a valuation allowance of $16.3 million against certain deferred tax assets primarily attributable to state net operating loss carryovers.

      

 

 

 

December 31,

 

 

 

2020

 

 

2019

 

 

 

(Dollars in millions)

 

Tax Effect of Items That Comprise a Significant

   Portion of the Net Deferred Tax Asset and Deferred

   Tax Liability

 

 

 

 

 

 

 

 

Deferred Tax Asset:

 

 

 

 

 

 

 

 

Employment related accruals

 

$

9.8

 

 

$

41.6

 

Other

 

 

7.5

 

 

 

 

Foreign tax credit carryover and other credit

   carryovers

 

 

0.2

 

 

 

0.3

 

Net operating loss carryforwards

 

 

125.9

 

 

 

82.7

 

Total gross deferred tax asset

 

 

143.4

 

 

 

124.6

 

Valuation allowance

 

 

(16.3

)

 

 

(15.1

)

Total deferred tax asset

 

$

127.1

 

 

$

109.5

 

Deferred Tax Liability:

 

 

 

 

 

 

 

 

Intangibles

 

$

(61.7

)

 

$

(57.3

)

Other

 

 

(55.2

)

 

 

(32.0

)

Total deferred tax liability

 

 

(116.9

)

 

 

(89.3

)

Net deferred tax asset (liability)

 

$

10.2

 

 

$

20.2

 

 

 

 

 

 

December 31,

 

 

 

2020

 

 

2019

 

 

 

(Dollars in millions)

 

Net Deferred Tax by Geography

 

 

 

 

 

 

 

 

U.S.

 

$

22.0

 

 

$

32.2

 

International

 

 

(11.8

)

 

 

(12.0

)

Total

 

$

10.2

 

 

$

20.2

 

 

As of December 31, 2020, we had federal, state, and foreign net operating loss carryovers, which will reduce future taxable income when utilized. Approximately $83.2 million in net federal tax benefit is available from the loss carryovers and an additional $0.2 million is available in federal tax credit carryovers. $53.6 million of the federal net operating loss tax benefit will expire from 2031 to 2037. The remaining $29.6 million has an indefinite carryover period. The state loss carryovers and foreign loss carryovers will result in a tax benefit of approximately $34.2 million and $8.5 million, respectively, when utilized. The state net operating loss carryovers will begin to expire in 2021. The majority of the foreign operating loss carryovers have an indefinite carryover period. The federal credit carryovers are composed of foreign tax credits, which will begin to expire in 2021; research credits, which will begin to expire in 2027; and alternative minimum tax credits, which have no expiration date.

We file income tax returns in the U.S. federal jurisdiction, and various states and foreign jurisdictions. With a few exceptions, we are no longer subject to U.S. federal, state and local, or non-U.S. income tax examinations by tax authorities for years before 2016.

The following table summarizes the activity for unrecognized tax benefits:

 

 

 

Year Ended

December 31,

 

 

 

2020

 

 

2019

 

 

 

(Dollars in millions)

 

Federal, State and Foreign Tax

 

 

 

 

 

 

 

 

Beginning unrecognized tax balance

 

$

1.5

 

 

$

1.3

 

Increase prior period positions

 

 

0.1

 

 

 

0.1

 

Increase current period positions

 

 

0.2

 

 

 

0.2

 

Decrease prior period positions

 

 

 

 

 

(0.1

)

Ending unrecognized tax benefits

 

$

1.8

 

 

$

1.5

 

 

The total amount of unrecognized tax benefits as of December 31, 2020, was $1.8 million including $0.3 million of accrued interest and penalties. Of the total amount of unrecognized tax benefits, $1.8 million represents the amount that, if recognized, would impact our effective income tax rate as of December 31, 2020. It is expected that the amount of unrecognized tax benefits will change in the next 12 months; however, we cannot reasonably estimate the amount of the change. We do not expect the change to have a significant impact on our results of operations or financial condition.

 

The Tax Cut and Jobs Act legislation of 2017 imposed a mandatory transition tax on the unremitted earnings of our international subsidiaries and generally eliminated US taxes on foreign subsidiary distributions for years beginning after December 31, 2017. As of December 31, 2020, we have $288.7 million of unremitted foreign earnings. We consider $236.0 million of the unremitted earnings to be indefinitely reinvested. For the portion of the unremitted earnings not considered indefinitely reinvested, $52.7 million, we have provided a deferred tax liability of $2.6 million, which represents the expected withholding tax cost of repatriating such earnings. In the event the portion of the unremitted earnings considered to be indefinitely reinvested were repatriated, we would incur a withholding tax expense of approximately $11.0 million.