(11) Income Taxes

Income (loss) from continuing operations before income taxes and the (provision for) benefit from income taxes consisted of the following:

	Year ended December 31,
	2014			2013			2012
Income (loss) from continuing operations:
United States	$	474.1		$	212.7		$	(223.6	)
Foreign		120.1			58.9			44.2

	$	594.2		$	271.6		$	(179.4	)


(Provision for) benefit from income taxes:
Current:
United States	$	(261.7	)	$	65.5		$	(1.4	)
Foreign		(34.1	)		(30.0	)		(20.9	)

Total current		(295.8	)		35.5			(22.3	)

Deferred and other:
United States		111.2			(123.9	)		1.2
Foreign		(29.5	)		28.1			35.3

Total deferred and other		81.7			(95.8	)		36.5

Total (provision) benefit	$	(214.1	)	$	(60.3	)	$	14.2

The reconciliation of income tax computed at the U.S. federal statutory tax rate to our effective income tax rate was as follows:

	Year ended December 31,
	2014			2013			2012
Tax at U.S. federal statutory rate		35.0	%		35.0	%		35.0	%
State and local taxes, net of U.S. federal benefit		1.8			1.5			(0.5	)
U.S. credits and exemptions		(1.6	)		(3.9	)		2.8
Foreign earnings taxed at lower rates		(2.3	)		(10.7	)		14.0
Audit settlements with taxing authorities		(2.0	)		0.2			15.4
Adjustments to uncertain tax positions		(2.1	)		0.8			(3.0	)
Changes in valuation allowance		6.2			(0.2	)		(6.2	)
Tax on repatriation of foreign earnings		2.7			(0.5	)		(8.4	)
Goodwill impairment and basis adjustments		(1.0	)		—			(41.8	)
Other		(0.7	)		—			0.6

		36.0	%		22.2	%		7.9	%

Significant components of our deferred tax assets and liabilities were as follows:

	As of December 31,
	2014			2013
Deferred tax assets:
NOL and credit carryforwards	$	266.2		$	229.8
Pension, other postretirement and postemployment benefits		116.9			95.5
Payroll and compensation		67.5			63.5
Legal, environmental and self-insurance accruals		45.8			42.3
Working capital accruals		34.7			26.8
Other		47.5			45.1

Total deferred tax assets		578.6			503.0
Valuation allowance		(152.9	)		(149.3	)

Net deferred tax assets		425.7			353.7

Deferred tax liabilities:
Intangible assets recorded in acquisitions		277.3			285.9
Basis difference in affiliates		184.2			152.1
Accelerated depreciation		64.8			69.3
Other		36.5			25.8

Total deferred tax liabilities		562.8			533.1

	$	(137.1	)	$	(179.4	)

General Matters

Deferred income taxes reflect the net tax effects of temporary differences between the carrying amounts of assets and liabilities for financial reporting purposes and the amounts used for income tax purposes. We periodically assess deferred tax assets to determine if they are likely to be realized and the adequacy of deferred tax liabilities, incorporating the results of local, state, federal and foreign tax audits in our estimates and judgments.

At December 31, 2014, we had the following tax loss carryforwards available: state tax loss carryforwards of approximately $362.0 and tax losses of various foreign jurisdictions of approximately $874.8. We also had federal and state tax credit carryforwards of $16.9. Of these amounts, approximately $3.9 expire in 2015 and $426.6 expire at various times between 2015 and 2034. The remaining carryforwards have no expiration date.

Realization of deferred tax assets, including those associated with net operating loss and credit carryforwards, is dependent upon generating sufficient taxable income in the appropriate tax jurisdiction. We believe that it is more likely than not that we may not realize the benefit of certain of these deferred tax assets and, accordingly, have established a valuation allowance against certain of these deferred tax assets. Although realization is not assured for the remaining deferred tax assets, we believe it is more likely than not that the deferred tax assets will be realized through future taxable earnings or tax planning strategies. However, deferred tax assets could be reduced in the near term if our estimates of taxable income are significantly reduced or tax planning strategies are no longer viable. The valuation allowance increased by $3.6 in 2014 and increased by $21.2 in 2013. Of the net increase in 2014, $36.5 was recognized as an increase in tax expense from continuing operations. Of the net increase in 2013, $0.5 was recognized as a decrease in tax expense from continuing operations.

The amount of income tax that we pay annually is dependent on various factors, including the timing of certain deductions. These deductions can vary from year to year, and, consequently, the amount of income taxes paid in future years will vary from the amounts paid in prior years.

Undistributed Foreign Earnings

In general, it is our practice and intention to reinvest the earnings of our non-U.S. subsidiaries in those operations. However, in the fourth quarter of 2014, our Board of Directors approved a plan for a tax-free spin-off of our Flow Technology reportable segment and our Hydraulic Technologies business and the creation of a new stand-alone, publicly-traded company. In connection the planned spin-off transaction, we elected to repatriate certain earnings of our non-U.S. subsidiaries during the quarter and provided for U.S. and foreign withholding taxes of $18.6 on such foreign dividends and undistributed earnings that were no longer considered to be indefinitely reinvested.

As of December 31, 2014, we had not recorded a provision for U.S. or foreign withholding taxes on approximately $1,265.0 of the excess of the amount for financial reporting over the tax basis of investments in foreign subsidiaries that are essentially permanent in duration. Generally, such amounts become subject to U.S. taxation upon the remittance of dividends and under certain other circumstances. It is not practicable to estimate the amount of a deferred tax liability related to the undistributed earnings of these foreign subsidiaries, in the event that these earnings are no longer considered to be indefinitely reinvested, due to the hypothetical nature of the calculation.

There are discrete amounts of foreign earnings (approximately $278.0), primarily related to the gain on sale of our Service Solutions business, where we do plan to repatriate the earnings in the future. During 2012, we provided $100.8 of U.S. and foreign withholding taxes on such earnings, with $91.8 of such amount recorded to discontinued operations.

Unrecognized Tax Benefits

As of December 31, 2014, we had gross unrecognized tax benefits of $63.3 (net unrecognized tax benefits of $33.9), of which $33.3, if recognized, would impact our effective tax rate from continuing operations. Similarly, at December 31, 2013 and 2012, we had gross unrecognized tax benefits of $128.4 (net unrecognized tax benefits of $72.9) and $108.4 (net unrecognized tax benefits of $72.5), respectively.

We classify interest and penalties related to unrecognized tax benefits as a component of our income tax provision. As of December 31, 2014, gross accrued interest totaled $5.9 (net accrued interest of $4.9), while the related amounts as of December 31, 2013 and 2012 were $12.4 (net accrued interest of $8.6) and $12.8 (net accrued interest of $8.6), respectively. Our income tax (provision) benefit for the years ended December 31, 2014, 2013 and 2012 included gross interest income of $0.9, $0.2 and $2.9, respectively, resulting from a reduction in our liability for uncertain tax positions. As of December 31, 2014, we had no accrual for penalties included in our unrecognized tax benefits, while the related amount as of December 31, 2013 and 2012 was $7.1. Our income tax (provision) benefit for the year ended December 31, 2014 included a benefit of $7.1 for the reversal of penalties previously accrued, resulting primarily from audit settlements during the year. The years ended December 31, 2013 and 2012 included penalties of $0.0 and $1.5, respectively.

Based on the outcome of certain examinations or as a result of the expiration of statutes of limitations for certain jurisdictions, we believe that within the next 12 months it is reasonably possible that our previously unrecognized tax benefits could decrease by approximately $10.0 to $15.0. The previously unrecognized tax benefits relate to a variety of tax matters relating to deemed income inclusions, transfer pricing and various state matters.

The aggregate changes in the balance of unrecognized tax benefits for the years ended December 31, 2014, 2013 and 2012 were as follows:

	Year ended December 31,
	2014			2013			2012
Unrecognized tax benefit — opening balance	$	128.4		$	108.4		$	120.4
Gross increases — tax positions in prior period		3.7			0.5			20.6
Gross decreases — tax positions in prior period		(36.9	)		(2.3	)		(33.9	)
Gross increases — tax positions in current period		11.7			28.4			11.2
Settlements		(28.2	)		(1.1	)		(7.1	)
Lapse of statute of limitations		(14.7	)		(5.5	)		(2.7	)
Change due to foreign currency exchange rates		(0.7	)		—			(0.1	)

Unrecognized tax benefit — ending balance	$	63.3		$	128.4		$	108.4

Other Tax Matters

During 2014, our income tax provision was impacted by the U.S. income taxes provided in connection with the $491.2 gain on the sale of our interest in EGS and by the following income tax charges: (i) $19.6 related to net increases in valuation allowances recorded against certain foreign deferred income tax assets, including $5.1 for which the related tax benefits are no longer expected to be realized due to legal entity reorganization actions that are required in connection with the planned spin-off transaction previously discussed, (ii) $18.6 related to the repatriation of certain earnings of our non-U.S. subsidiaries and (iii) $6.0 of foreign income taxes related to reorganization actions undertaken to facilitate the planned spin-off transaction. The impact of these items was partially offset by the following income tax benefits: (i) $28.6 of tax benefits related to various audit settlements, statute expirations and other adjustments to liabilities for uncertain tax positions, with the most notable being the closure of our U.S. tax examination for the years 2008 through 2011, and (ii) $6.4 of tax benefits related to a loss on an investment in a foreign subsidiary.

During 2013, our income tax provision was impacted by the following income tax benefits: (i) $9.5 related to net reductions in valuation allowances recorded against certain foreign deferred income tax assets; (ii) $6.5 related to various audit settlements and statute expirations; and (iii) $4.1 associated with the Research and Experimentation Credit generated in 2012.

During 2012, our income tax benefit was impacted by: (i) an income tax benefit of $26.3 associated with the $281.4 impairment charge recorded for our Cooling reporting unit, as the majority of the goodwill for the Cooling reporting unit has no basis for income tax purposes; (ii) taxes provided of $15.4 on foreign dividends and undistributed earnings that were no longer considered to be indefinitely reinvested; (iii) incremental tax expense of $6.1 associated with the deconsolidation of our dry cooling business in China, as the goodwill allocated to the transaction was not deductible for income tax purposes; and (iv) valuation allowances that were recorded against deferred income tax assets during the year of $5.4. The unfavorable impact of these items was offset partially by income tax benefits of $22.3 associated with audit closures, settlements, statute expirations, and other changes in the accrual for uncertain tax positions, with the most notable being the closure of our German tax examination for the years 2005 through 2009.

We perform reviews of our income tax positions on a continuous basis and accrue for potential uncertain positions when we determine that an uncertain position meets the criteria of the Income Taxes Topic of the Codification. Accruals for these uncertain tax positions are recorded in "Income taxes payable" and "Deferred and other income taxes" in the accompanying consolidated balance sheets based on the expectation as to the timing of when the matters will be resolved. As events change and resolutions occur, these accruals are adjusted, such as in the case of audit settlements with taxing authorities.

We have filed our federal income tax returns for the 2012 and 2013 tax years and those returns are subject to examination. The IRS is currently examining the 2012 tax return year. With regard to open tax years, we believe any contingencies are adequately provided for.

State income tax returns generally are subject to examination for a period of three to five years after filing the respective tax returns. The impact on such tax returns of any federal changes remains subject to examination by various states for a period of up to one year after formal notification to the states. We have various state income tax returns in the process of examination, administrative appeal or litigation. We believe any uncertain tax positions related to these examinations have been adequately provided for.

We have various foreign income tax returns under examination. The most significant of these are in Denmark for the 2006, 2007, 2009, and 2010 tax years and South Africa for the 2005 to 2010 tax years. We believe that any uncertain tax positions related to these examinations have been adequately provided for.

An unfavorable resolution of one or more of the above matters could have a material adverse effect on our results of operations or cash flows in the quarter and year in which an adjustment is recorded or the tax is due or paid. As audits and examinations are still in process or we have not yet reached the final stages of the appeals process, the timing of the ultimate resolution and any payments that may be required for the above matters cannot be determined at this time.