Income Taxes

The consolidated income tax provision includes taxes attributable to the controlling interest and, to a lesser extent, taxes attributable to non-controlling interests as follows:



	For the Years Ended December 31,
	2012			2013			2014
Controlling Interests:
Current tax	$	61.0		$	153.1		$	149.8
Intangible-related deferred taxes	22.7			38.1			47.8
Other deferred taxes	(12.1		)	(6.2		)	15.8
Total controlling interests	71.6			185.0			213.4
Non-controlling Interests:
Current tax	$	11.7		$	13.3		$	15.3
Deferred taxes	0.5			(4.2		)	(0.8		)
Total non-controlling interests	12.2			9.1			14.5
Provision for income taxes	$	83.8		$	194.1		$	227.9
Income before income taxes (controlling interest)	$	245.6		$	545.5		$	665.5
Effective tax rate attributable to controlling interests⁽¹⁾	29.2		%	33.9		%	32.1		%

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(1)	Taxes attributable to the controlling interest divided by Income before income taxes (controlling interest).

A summary of the consolidated provision for income taxes is as follows:



	For the Years Ended December 31,
	2012			2013			2014
Current:
Federal	$	14.5		$	104.1		$	93.8
State	14.2			21.1			27.1
Foreign	44.0			41.2			44.2
Total current	72.7			166.4			165.1
Deferred:
Federal	19.8			38.1			72.5
State	4.6			8.9			1.1
Foreign	(13.3		)	(19.3		)	(10.8		)
Total deferred	11.1			27.7			62.8
Provision for income taxes	$	83.8		$	194.1		$	227.9

The components of income before income taxes consisted of the following:



	For the Years Ended December 31,
	2012		2013		2014
Domestic	$	238.6	$	604.0	$	784.1
International	256.6		259.7		229.5
	$	495.2	$	863.7	$	1,013.6

The Company's effective income tax rate differs from the amount computed by using income before income taxes and applying the U.S. federal income tax rate because of the effect of the following items:



	For the Years Ended December 31,
	2012		2013		2014
Tax at U.S. federal income tax rate	35.0	%	35.0	%	35.0	%
State income taxes, net of federal benefit⁽¹⁾	3.5		2.8		2.1
Non-deductible expenses	0.7		0.3		0.3
Valuation allowance⁽¹⁾	(4.7	)	(0.3	)	—
Effect of Non-US operations	(3.3	)	(2.5	)	(5.3	)
Effect of changes in tax law, rates	(2.0	)	(1.4	)	—
Effect of income from non-controlling interests	(12.2	)	(11.4	)	(9.6	)
	17.0	%	22.5	%	22.5	%

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(1)	State income taxes includes changes related to state valuation allowances. Valuation allowance includes changes in federal valuation allowances.

In 2012, the Company reduced its valuation allowance $11.5 million for its foreign loss carryforwards and realized a deferred tax benefit of $7.3 million from the revaluation of its deferred taxes from a reduction in corporate tax rates in the United Kingdom.

In 2013, the Company realized deferred tax benefits of $5.9 million and $11.2 million on investments in foreign subsidiaries that became permanent in duration and from the revaluation of its deferred taxes from a reduction in corporate tax rates in the United Kingdom, respectively.

In 2014, the Company reduced its valuation allowance $6.5 million for state net operating loss carryforwards and realized a deferred tax benefit of $24.5 million on investments in foreign subsidiaries that became permanent in duration.

These changes decreased the controlling interest effective tax rate 6.7%, 2.7% and 4.7% in the years ended December 31, 2012, 2013 and 2014, respectively.

The Company does not provide for deferred taxes on the excess of the financial reporting basis over the tax basis in its investments in foreign subsidiaries that are permanent in duration. This amount becomes taxable upon a repatriation of assets from a sale or liquidation of the subsidiary. As of December 31, 2014, the amount of such temporary difference was approximately $139.4 million. The deferred taxes not recognized at December 31, 2014 for this temporary difference are approximately $52.4 million.

The components of deferred tax assets and liabilities are as follows:



	December 31,
	2013			2014
Deferred Tax Assets
State net operating loss carryforwards	$	29.3		$	15.2
Deferred compensation	29.1			26.8
Tax benefit of uncertain tax positions	16.2			16.0
Accrued expenses	17.6			19.6
Foreign loss carryforwards	9.1			11.5
Other	—			1.4
Total deferred tax assets	101.3			90.5
Valuation allowance	(36.6		)	(18.4		)
Deferred tax assets, net of valuation allowance	$	64.7		$	72.1
Deferred Tax Liabilities
Intangible asset amortization	$	(241.3	)	$	(270.9	)
Convertible securities interest	(144.7		)	(92.5		)
Non-deductible intangible amortization	(101.5		)	(126.4		)
Deferred revenue	(32.1		)	(74.0		)
Other	(2.0		)	—
Total deferred tax liabilities	(521.6		)	(563.8		)
Net deferred tax liability	$	(456.9	)	$	(491.7	)

Deferred tax liabilities are primarily the result of tax deductions for the Company's intangible assets and convertible securities. The Company amortizes most of its intangible assets for tax purposes only, reducing its tax basis below its carrying value for financial statement purposes and generating deferred taxes each reporting period. The Company's convertible securities also generate deferred taxes because the Company's tax deductions are higher than the interest expense recorded for financial statement purposes.

At December 31, 2014, the Company has state net operating loss carryforwards which expire over an 18-year period and foreign loss carryforwards which expire over a 20-year period. The Company has established a valuation allowance to offset these carryforwards because of the uncertainty of realizing their full value.

In 2012 and 2013, the Company reduced its valuation allowance $11.5 million and $1.6 million, respectively from improved projections of taxable income.

In 2014, the Company reduced its valuation allowance $15.7 million on state net operating loss carryforwards from improved projections of taxable income, and increased state uncertain tax positions by $9.2 million for a net $6.5 million state tax benefit.

The Company had uncertain tax positions of $22.6 million, $20.4 million and $28.8 million as of December 31, 2012, 2013 and 2014, respectively. These amounts included $2.2 million, $1.7 million and $1.6 million of interest and related charges, respectively. At December 31, 2012, 2013 and 2014, these liabilities also included $19.4 million, $17.2 million and $26.4 million, respectively, for tax positions that, if recognized, would affect the Company's effective tax rate.

A reconciliation of the beginning and ending amount of unrecognized tax benefits is as follows:



	For the Years Ended December 31,
	2012			2013			2014
Balance, as of January 1	$	21.2		$	22.6		$	20.4
Additions based on current year tax positions	5.9			4.1			2.6
Additions based on prior years' tax positions	5.2			—			10.8
Reductions for prior years' tax provisions	(5.4		)	(0.1		)	—
Reductions related to lapses of statutes of limitations	(4.6		)	(5.4		)	(4.1		)
Additions (reductions) related to foreign exchange rates	0.3			(0.8		)	(0.9		)
Balance, as of December 31	$	22.6		$	20.4		$	28.8

During 2012, uncertain tax positions decreased $5.4 million as a result of the recognition of tax benefits from the transfer of interests in an Affiliate. This decrease was offset by a $5.2 million provision for added foreign exposure for prior years. During 2014, uncertain tax positions increased $10.8 million, principally for the uncertain nature of several of its state net operating loss carryforwards. The Company does not anticipate that this liability will change significantly over the next twelve months.

The Company periodically has tax examinations in the U.S. and foreign jurisdictions. Examination outcomes, and any related settlements, are subject to significant uncertainty. The completion of examinations may result in the payment of additional taxes and/or the recognition of tax benefits. The Company is generally no longer subject to income tax examinations by any tax authorities for years before 2009.