6. INCOME TAXES

The U.S. and international components of income before taxes are as follows (in millions):



	Year Ended December 31,
	2014		2013		2012
U.S.	$	30.6	$	5.7	$	110.6
International	101.0		106.7		119.3
Income before taxes	$	131.6	$	112.4	$	229.9

The provision for income taxes consists of the following (in millions):



	Year Ended December 31,
	2014			2013			2012
Current tax expense (benefit):
U.S. Federal	$	9.6		$	(5.0	)	$	34.4
State	3.8			0.6			4.1
International	35.6			38.3			37.3
Current tax expense	49.0			33.9			75.8
Deferred tax (benefit) expense:
U.S. Federal	1.5			4.8			(3.1		)
State	(0.2		)	(0.1		)	(0.9		)
International	(7.3		)	(9.4		)	(6.3		)
Deferred tax benefit	(6.0		)	(4.7		)	(10.3		)
Non-current tax expense (benefit)	(0.3		)	5.4			(1.1		)
Provision for income taxes	$	42.7		$	34.6		$	64.4

The reconciliation between our effective tax rate on income before taxes and the statutory tax rate is as follows:



	Year Ended December 31,
	2014		2013		2012
U.S. statutory tax rate	35	%	35	%	35	%
Impact of foreign operations	(4	)	(6	)	(3	)
Research tax credits	(3	)	(6	)	—
Nontaxable subsidies	(2	)	(2	)	(1	)
Tax settlements and changes to unrecognized tax benefits	(1	)	5		—
Fines and penalties	3		1		—
Contingent consideration	—		(1	)	(2	)
Other	4		5		(1	)
Provision for income taxes	32	%	31	%	28	%

The effective tax rates for 2014 and 2013 are approximately the same. The effective tax rate for 2014 includes a lower tax benefit of research tax credits because the effective tax rate for 2013 included a significant tax benefit related to the 2012 U.S. federal research credit, which was retroactively reinstated on January 2, 2013. The additional tax benefit of research credits in 2013 was offset by an increase in tax liabilities for unrecognized tax benefits and audit settlements in our foreign jurisdictions.

The effective tax rates for all three periods were lower than the U.S. statutory rate primarily due to tax benefits from differences between U.S. and foreign statutory tax rates, and research and development tax credits. Our foreign income is earned primarily in Switzerland and France. Jurisdictions in which we operate that have statutory tax rates that are significantly lower than the U.S. statutory tax rate of 35% include Switzerland, Russia, the U.K. and Singapore.

Our effective tax rate may be impacted in the future, either favorably or unfavorably, by many factors including, but not limited to, changes to statutory tax rates, changes in tax laws or regulations, tax audits and settlements, and generation of tax credits.

Deferred tax assets and liabilities reflect the tax effects of losses, credits, and temporary differences between the carrying amounts of assets and liabilities for financial reporting purposes and the amounts used for income tax purposes. Significant components of deferred tax assets and liabilities are as follows (in millions):



	December 31,
	2014			2013
Deferred tax assets:
Bad debt, inventory and warranty accruals	$	25.3		$	27.5
Legal reserves	2.0			12.0
Other post-employment benefits, vacation and other reserves	23.6			22.2
Tax credit and net operating loss carryforwards	60.5			62.3
Other	28.4			19.0
Total gross deferred tax assets	139.8			143.0
Valuation allowance	(58.6		)	(64.0		)
Total deferred tax assets	81.2			79.0
Deferred tax liabilities:
Property and equipment	12.9			17.2
Investments and intangible assets	158.2			147.0
Total deferred tax liabilities	171.1			164.2
Net deferred tax liabilities	$	(89.9	)	$	(85.2	)

At December 31, 2014, Bio-Rad’s international subsidiaries had combined net operating loss carryforwards of $106.8 million. Of these loss carryforwards, $105.6 million have no expiration date. We believe that it is more likely than not that the benefit from most of these net operating loss carryforwards will not be realized. We have provided a valuation allowance of $23.6 million relating to these net operating loss carryforwards.

At December 31, 2014, Bio-Rad had U.S. Federal net operating loss carryforwards of approximately $10 million as a result of acquisitions. These carryforwards are subject to limitation on their utilization and will expire between 2018 and 2034. At December 31, 2014, Bio-Rad had U.S. Federal research tax credit carryforwards of $5.3 million, $1.9 million of which are subject to limitations on their utilization.

At December 31, 2014, Bio-Rad had approximately $53 million of California net operating loss carryforwards related to the acquisition of QuantaLife. We believe that it is more likely than not that the benefit from these net operating loss carryforwards will not be realized and have recorded a full valuation allowance against these losses. At December 31, 2014, Bio-Rad had a deferred tax asset of $20.2 million relating to California research tax credit carryforwards, including $2.0 million from the acquisition of QuantaLife, which may be carried forward indefinitely. Based on our judgment and consistent with prior years, we have recorded a full valuation allowance against the deferred tax asset.

We believe that it is more likely than not that certain of these deferred tax assets described above will not be realized in the foreseeable future. If or when recognized, the tax benefits relating to any reversal of the valuation allowance on deferred tax assets at December 31, 2014 will be recognized as a reduction of income tax expense.

The tax years subject to examination by tax authorities in major jurisdictions that Bio-Rad operates in include the years 2009 and forward for the U.S., and the years 2008 and forward for certain foreign jurisdictions, including France, Switzerland and Germany.

The following is a tabular reconciliation of the total amounts of unrecognized tax benefits (in millions):



	2014			2013			2012
Unrecognized tax benefits – January 1	$	16.2		$	12.6		$	11.3
Additions to tax positions related to prior years	1.7			4.7			1.3
Reductions to tax positions related to prior years	(1.5		)	(0.8		)	(0.8		)
Additions to tax positions related to the current year	1.6			2.0			1.6
Settlements	(0.4		)	(0.3		)	—
Lapse of statute of limitations	(2.6		)	(1.7		)	(3.0		)
Acquisitions	—			—			2.2
Currency translation	(0.8		)	(0.3		)	—
Unrecognized tax benefits – December 31	$	14.2		$	16.2		$	12.6

Substantially all our unrecognized tax benefits at December 31, 2014, 2013 and 2012 would affect the effective tax rate if recognized.

Bio-Rad recognizes accrued interest and penalties related to unrecognized tax benefits as income tax expense. Related to the unrecognized tax benefits noted above, Bio-Rad has accrued interest of $3.8 million, $3.4 million and $1.9 million as of December 31, 2014, 2013 and 2012, respectively.

At December 31, 2014, we believe that it is reasonably possible that $6.8 million of our unrecognized tax benefits may be recognized by the end of 2015 as a result of statute lapses. These benefits are related to uncertainty regarding sustainability of certain deductions and credits for tax years that remain subject to examination by the relevant tax authorities.

In general, it is our practice and intention to reinvest the earnings of our non-U.S. subsidiaries in their operations. As of December 31, 2014, Bio-Rad had not made a provision for U.S. or additional foreign withholding taxes on approximately $512 million 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 remittance of dividends and under certain other circumstances. If these earnings were repatriated to the U.S., the deferred tax liability associated with these temporary differences would be approximately $106 million.