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INCOME TAXES
6 Months Ended
Jun. 30, 2018
INCOME TAXES  
INCOME TAXES

NOTE 5 – INCOME TAXES

The TCJA was enacted in the U.S. on December 22, 2017. The TCJA lowered the corporate tax rate from 35.0% to 21.0%, and imposed a one-time transition tax on unremitted earnings as of the end of 2017, among other changes.  New provisions for 2018 include, most notably, a tax on GILTI and BEAT.  The SEC issued SAB 118 to address the U.S. GAAP application of the TCJA.  SAB 118 provides us up to a year to finalize accounting for the impacts of the TCJA.

The Company estimated provisional tax amounts related to the transition tax and components of the revaluation of deferred tax assets and liabilities for the period ended December 31, 2017.  We recognized a net tax charge of approximately $24.7 million, comprised of a provisional charge of $31.6 million for the transition tax and a provisional benefit of $6.8 million related to the corporate rate change.  For the quarter ended June 30, 2018, the Company recorded a benefit of $3.5 million to reflect an adjustment to the calculation of the transition tax.  This adjustment reflects the guidance given in Treasury Notice 2018-26, which allows for the allocation of tax expense in computing the earnings and profits as of November 2, 2017 for purposes of the transition tax.  The Company expects both provisional amounts to be finalized in the second half of 2018 when the 2017 tax return is filed. The Company has elected to account for the tax on GILTI as a period cost and not as a measure of deferred taxes in the current period.

The reported effective tax rate increased to 25.5% for the quarter ended June 30, 2018 compared to 18.1% for the quarter ended June 30, 2017, resulting in an increase to the provision for income taxes of approximately $4.7 million. The current year rate includes the benefit from a true up of the provisional transition tax liability, which reduced the effective tax rate by 4.6% and was partially offset by the charges recorded in the period for the GILTI and BEAT taxes, which increased the effective tax rate by 1.3%.  The tax rate for 2017 reflects larger tax benefits from employee share-based compensation, which reduced the effective tax rate by 5.2%, and a benefit from repatriation activities undertaken in 2017, which reduced the effective tax rate by 4.1%.

The reported effective tax rate increased to 26.3% for the six months ended June 30, 2018 compared to 21.5% for the six months ended June 30, 2017, resulting in an increase to the provision for income taxes of approximately $9.0 million. The 2018 rate includes the benefit from a true up of the provisional transition tax liability, which reduced the effective tax rate by 2.2% and was offset by the charges recorded in the period for the GILTI and BEAT taxes, which increased the effective tax rate by 2.9%.  The tax rate for 2017 reflects larger tax benefits from employee share-based compensation, which reduced the effective tax rate by 1.4%, and a benefit from repatriation activities undertaken in 2017, which reduced the effective tax rate by 1.9%.

The Company had approximately $3.3 million and $3.1 million recorded for income tax uncertainties as of June 30, 2018 and December 31, 2017, respectively.  The uncertain amounts, if recognized, that would impact the effective tax rate are $3.3 million and $3.1 million, respectively. The Company estimates that it is reasonably possible that the liability for uncertain tax positions will decrease by no more than $1.4 million in the next twelve months from the resolution of various uncertain positions as a result of the completion of tax audits, litigation and the expiration of the statute of limitations in various jurisdictions.