Taxes	6 Months Ended
Jun. 30, 2021
Taxes
Taxes	9. Taxes The Company’s effective tax rate for the three months ended June 30, 2021 decreased to 11.7 percent from 28.7 percent during the three months ended June 30, 2020. The decrease in the effective income tax rate was primarily driven by a discrete tax benefit of $30 million due to the reversal of an accrual for withholding tax on the unremitted earnings of a foreign subsidiary. The remaining change in the effective tax rate was driven by an increase in the value of the Mexican peso against the U.S. dollar during the three months ended June 30, 2021, as compared to a decrease during the three months ended March 31, 2021. The change in the value of the Mexican peso against the U.S. dollar produced a taxable translation loss during the three months ended June 30, 2021, compared to a gain during the three months ended June 30, 2020, on net-U.S.-dollar-monetary assets held in Mexico for which there was no corresponding loss or gain in pre-tax income. The effective tax rate for the six months ended June 30, 2021 increased to 464.7 percent from 37.0 percent for the six months ended June 30, 2020. The primary cause of the increase in the effective tax rate was a $360 million impairment charge related to net assets that will be contributed to a joint venture, as described in Note 5 of the Notes to the Condensed Consolidated Financial Statements. There was no corresponding income tax benefit recorded with respect to the impairment. The remaining change in the effective income tax rate was primarily driven by a 22 percent decrease in the value of the Mexican peso against the U.S. dollar during the six months ended June 30, 2020. The decrease in the value of the Mexican peso against the U.S. dollar produced taxable translation gains on net-U.S.-dollar-monetary assets held in Mexico for which there was no corresponding gain in pre-tax income. Consequently, the Company recorded a discrete tax expense of $22 million in the six months ended June 30, 2020, as compared to a $1 million discrete tax benefit in the six months ended June 30, 2021. In January 2019, the Company’s Brazilian subsidiary received a favorable decision from the Federal Court of Appeals in Sao Paulo, Brazil, related to certain indirect taxes collected in prior years. The Company finalized its calculation of the amount of the credits and interest due from the favorable decision, concluding that the Company could be entitled to approximately $66 million of credits spanning a period from 2005 to 2018. The Department of Federal Revenue of Brazil, however, issued an Internal Ruling in which it charged that the Company is entitled to only $22 million of the calculated indirect tax credits and interest for the period from 2005 to 2014. The Brazil National Treasury filed a motion for clarification with the Brazilian Supreme Court, asking the Court, among other things, to modify the lower court’s decision to approve the Internal Ruling, which could impact the decision in favor of the Company. During the year ended December 31, 2020, the Company received another favorable court judgment that clarified the calculation of the Company’s benefit, allowing the Company to claim gross treatment within the indirect tax claim calculation and a larger indirect tax claim against the government. As a result of the decision, the Company recorded an additional $35 million pre-tax benefit in the Consolidated Income Statement in Other income for the year ended December 31, 2020, related to the open period of 2005 to 2014. In May 2021, the Brazilian Supreme Court issued its ruling related to the calculation of certain indirect taxes, which affirmed the lower court rulings that the Company had received in previous years and affirmed that the Company is entitled to the previously recorded tax credits. The Supreme Court ruling ensures that the Company will be entitled to $15 million of additional credits from the period of 2015 to 2018 that was previously unrecorded pending a final court ruling. The Company recorded the $15 million of additional credits during the three months ended June 30, 2021 within Other Income (expense), net in the Condensed Consolidated Income Sheet. As of June 30, 2021, the Company has $64 million of future tax offsets recorded in Other assets and Prepaid expenses on the Condensed Consolidated Balance Sheets that result in deferred income taxes of $22 million. The tax offsets arose from the recovery of indirect taxes withheld and paid in 2021 and prior years. The Company will use the tax offsets to eliminate its Brazilian federal tax payments in 2021 and future years, including the income tax payable with respect to the indirect taxes recovered.

Taxes

6 Months Ended

Jun. 30, 2021

9. Taxes

The Company’s effective tax rate for the three months ended June 30, 2021 decreased to 11.7 percent from 28.7 percent during the three months ended June 30, 2020. The decrease in the effective income tax rate was primarily driven by a discrete tax benefit of $30 million due to the reversal of an accrual for withholding tax on the unremitted earnings of a foreign subsidiary. The remaining change in the effective tax rate was driven by an increase in the value of the Mexican peso against the U.S. dollar during the three months ended June 30, 2021, as compared to a decrease during the three months ended March 31, 2021. The change in the value of the Mexican peso against the U.S. dollar produced a taxable translation loss during the three months ended June 30, 2021, compared to a gain during the three months ended June 30, 2020, on net-U.S.-dollar-monetary assets held in Mexico for which there was no corresponding loss or gain in pre-tax income.

The effective tax rate for the six months ended June 30, 2021 increased to 464.7 percent from 37.0 percent for the six months ended June 30, 2020. The primary cause of the increase in the effective tax rate was a $360 million impairment charge related to net assets that will be contributed to a joint venture, as described in Note 5 of the Notes to the Condensed Consolidated Financial Statements. There was no corresponding income tax benefit recorded with respect to the impairment. The remaining change in the effective income tax rate was primarily driven by a 22 percent decrease in the value of the Mexican peso against the U.S. dollar during the six months ended June 30, 2020. The decrease in the value of the Mexican peso against the U.S. dollar produced taxable translation gains on net-U.S.-dollar-monetary assets held in Mexico for which there was no corresponding gain in pre-tax income. Consequently, the Company recorded a discrete tax expense of $22 million in the six months ended June 30, 2020, as compared to a $1 million discrete tax benefit in the six months ended June 30, 2021.

In January 2019, the Company’s Brazilian subsidiary received a favorable decision from the Federal Court of Appeals in Sao Paulo, Brazil, related to certain indirect taxes collected in prior years. The Company finalized its calculation of the amount of the credits and interest due from the favorable decision, concluding that the Company could be entitled to approximately $66 million of credits spanning a period from 2005 to 2018. The Department of Federal Revenue of Brazil, however, issued an Internal Ruling in which it charged that the Company is entitled to only $22 million of the calculated indirect tax credits and interest for the period from 2005 to 2014. The Brazil National Treasury filed a motion for clarification with the Brazilian Supreme Court, asking the Court, among other things, to modify the lower court’s decision to approve the Internal Ruling, which could impact the decision in favor of the Company. During the year ended December 31, 2020, the Company received another favorable court judgment that clarified the calculation of the Company’s benefit, allowing the Company to claim gross treatment within the indirect tax claim calculation and a larger indirect tax claim against the government. As a result of the decision, the Company recorded an additional $35 million pre-tax benefit in the Consolidated Income Statement in Other income for the year ended December 31, 2020, related to the open period of 2005 to 2014. In May 2021, the Brazilian Supreme Court issued its ruling related to the calculation of certain indirect taxes, which affirmed the lower court rulings that the Company had received in previous years and affirmed that the Company is entitled to the previously recorded tax credits. The Supreme Court ruling ensures that the Company will be entitled to $15 million of additional credits from the period of 2015 to 2018 that was previously unrecorded pending a final court ruling. The Company recorded the $15 million of additional credits during the three months ended June 30,

2021 within Other Income (expense), net in the Condensed Consolidated Income Sheet. As of June 30, 2021, the Company has $64 million of future tax offsets recorded in Other assets and Prepaid expenses on the Condensed Consolidated Balance Sheets that result in deferred income taxes of $22 million. The tax offsets arose from the recovery of indirect taxes withheld and paid in 2021 and prior years. The Company will use the tax offsets to eliminate its Brazilian federal tax payments in 2021 and future years, including the income tax payable with respect to the indirect taxes recovered.

- Definition

The entire disclosure for income taxes. Disclosures may include net deferred tax liability or asset recognized in an enterprise's statement of financial position, net change during the year in the total valuation allowance, approximate tax effect of each type of temporary difference and carryforward that gives rise to a significant portion of deferred tax liabilities and deferred tax assets, utilization of a tax carryback, and tax uncertainties information.

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