Income Taxes

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



	For the Years Ended December 31,
	2013			2014			2015
Controlling Interests:
Current tax	$	153.1		$	149.8		$	152.4
Intangible-related deferred taxes	38.1			47.8			77.7
Other deferred taxes	(6.2		)	15.8			21.2
Total controlling interests	185.0			213.4			251.3
Non-controlling Interests:
Current tax	$	13.3		$	15.3		$	9.8
Deferred taxes	(4.2		)	(0.8		)	(4.2		)
Total non-controlling interests	9.1			14.5			5.6
Provision for income taxes	$	194.1		$	227.9		$	256.9
Income before income taxes (controlling interest)	$	545.5		$	665.5		$	767.3
Effective tax rate attributable to controlling interests⁽¹⁾	33.9		%	32.1		%	32.8		%

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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 follows:



	For the Years Ended December 31,
	2013			2014			2015
Current:
Federal	$	104.1		$	93.8		$	106.3
State	21.1			27.1			18.3
Foreign	41.2			44.2			37.6
Total current	166.4			165.1			162.2
Deferred:
Federal	38.1			72.5			97.9
State	8.9			1.1			14.2
Foreign	(19.3		)	(10.8		)	(17.4		)
Total deferred	27.7			62.8			94.7
Provision for income taxes	$	194.1		$	227.9		$	256.9

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



	For the Years Ended December 31,
	2013		2014		2015
Domestic	$	604.0	$	784.1	$	827.6
International	259.7		229.5		263.0
	$	863.7	$	1,013.6	$	1,090.6

The Company’s effective income tax rate differed 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,
	2013		2014		2015
Tax at U.S. federal income tax rate	35.0	%	35.0	%	35.0	%
State income taxes, net of federal benefit⁽¹⁾	2.8		2.1		2.6
Effect of foreign operations	(2.5	)	(5.3	)	(3.5	)
Other	(1.4	)	0.3		(1.3	)
Effective tax rate (controlling interest)	33.9		32.1		32.8
Effect of income from non-controlling interests	(11.4	)	(9.6	)	(9.2	)
Effect tax rate	22.5	%	22.5	%	23.6	%

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⁽¹⁾	State income taxes included changes related to state valuation allowances.

In 2013, the Company realized deferred tax benefits of $7.2 million on investments in foreign subsidiaries deemed permanent in duration (including $5.9 million for subsidiaries that became permanent in duration in 2013) and $11.2 million ($7.6 million to the controlling interest) from the revaluation of its deferred taxes resulting from a reduction in corporate tax rates in the United Kingdom.

In 2014, the Company realized deferred tax benefits of $30.3 million on investments in foreign subsidiaries deemed permanent in duration (including $24.5 million for subsidiaries that became permanent in duration in 2014) and reduced its valuation allowance $6.5 million for state net operating loss carryforwards.

In 2015, the Company realized $17.1 million of tax benefits from investments in foreign subsidiaries deemed permanent in duration and $5.0 million from its indefinite reinvestment of certain 2015 foreign earnings. In 2015, the Company also realized $10.0 million ($6.5 million to the controlling interest) of deferred tax benefits resulting from a reduction in corporate tax rates in the United Kingdom.

The Company did not provide for deferred taxes on the excess of the financial reporting basis over the tax basis in its investments in foreign subsidiaries that were permanent in duration. This amount becomes taxable upon a repatriation of assets from a sale or liquidation of the subsidiary. As of December 31, 2015, the amount of such difference was $188.1 million. The deferred taxes not recognized at December 31, 2015 for this difference were $71.1 million.

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



	December 31,
	2014			2015
Deferred Tax Assets
Deferred compensation	$	26.8		$	30.5
State net operating loss carryforwards	15.2			17.1
Tax benefit of uncertain tax positions	16.0			14.6
Accrued expenses	19.6			4.4
Foreign loss carryforwards	11.5			12.3
Other	1.4			—
Total deferred tax assets	90.5			78.9
Valuation allowance	(18.4		)	(20.5		)
Deferred tax assets, net of valuation allowance	$	72.1		$	58.4
Deferred Tax Liabilities
Intangible asset amortization	$	(270.9	)	$	(320.2	)
Non-deductible intangible amortization	(126.4		)	(109.8		)
Convertible securities interest	(92.5		)	(99.8		)
Deferred income	(74.0		)	(92.8		)
Other	—			(1.5		)
Total deferred tax liabilities	(563.8		)	(624.1		)
Net deferred tax liability	$	(491.7	)	$	(565.7	)

Deferred tax liabilities were 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, 2015, the Company had state net operating loss carryforwards that expire over a 19-year period and foreign loss carryforwards that expire over a 20-year period. The Company had established a valuation allowance to offset a portion of these carryforwards because of the uncertainty of realizing their full value.

In 2014, the Company reduced its valuation allowance $15.7 million on state 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. In 2014, the Company also reduced its valuation allowance on loss carryforwards by $2.5 million.

In 2015, the Company increased its valuation allowance $2.1 million, principally for loss carryforwards deemed unrealizable.

The Company had uncertain tax positions of $20.4 million, $28.8 million and $26.9 million as of December 31, 2013, 2014 and 2015, respectively. These amounts included $1.7 million, $1.6 million and $1.8 million of interest and related charges, respectively. At December 31, 2013, 2014 and 2015, these liabilities also included $17.2 million, $26.4 million and $25.3 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 follows:



	For the Years Ended December 31,
	2013			2014			2015
Balance, as of January 1	$	22.6		$	20.4		$	28.8
Additions based on current year tax positions	4.1			2.6			2.2
Additions based on prior years’ tax positions	—			10.8			1.6
Reductions for prior years’ tax provisions	(0.1		)	—			—
Reductions related to lapses of statutes of limitations	(5.4		)	(4.1		)	(4.3		)
Additions (reductions) related to foreign exchange rates	(0.8		)	(0.9		)	(1.4		)
Balance, as of December 31	$	20.4		$	28.8		$	26.9

During 2014, uncertain tax positions increased $8.4 million, principally for the uncertain nature of several of its state net operating loss carryforwards. During 2015, uncertain tax positions decreased $1.9 million, principally from changes in foreign exchange rates. The Company does not anticipate that uncertain tax positions 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 was generally no longer subject to income tax examinations by any tax authorities for years before 2010.