Income Taxes

On December 22, 2017, the 2017 Tax Act was signed into law. The 2017 Tax Act included a number of changes to the U.S. Internal Revenue Code, including a reduction of the U.S. corporate income tax rate from 35% to 21% for tax years beginning after December 31, 2017, and a one-time transition tax on certain unrepatriated foreign earnings (the “Transition Tax”). Prospective changes from the 2017 Tax Act that began in 2018 include imposed limitations on the deductibility of executive compensation and interest, a general elimination of U.S. federal income taxes on dividends from foreign subsidiaries, and a new provision designed to tax global intangible low-taxed income ("GILTI"). The Company has made an accounting policy election to account for the tax effects of the GILTI provision as a period cost.

The Company recognized the income tax effects of the 2017 Tax Act in its financial statements for the year ended December 31, 2017, in accordance with Staff Accounting Bulletin No. 118, which provides SEC staff guidance for the application of ASC Topic 740, Income Taxes. The Company finalized its accounting for the income tax effects of the 2017 Tax Act in the fourth quarter of 2018 and there was no material change.

The table below summarizes significant components of deferred tax assets and liabilities.



	Year Ended December 31,
	2018			2017
Deferred tax assets
Allowance for doubtful accounts	$	11,792		$	11,279
Accrued vacation and bonus	23,545			23,896
Deferred rent	9,016			8,491
Share-based compensation	11,837			15,108
Notes receivable from employees	12,993			12,879
State net operating loss carryforward	3,510			3,586
Foreign net operating loss carryforward	9,857			12,075
Federal tax credit and capital loss carryforward	9,470			7,403
Deferred compensation	1,801			2,688
Other, net	1,129			7,159
Total deferred tax assets	94,950			104,564
Deferred tax liabilities
Revenue recognition	(5,087		)	(7,227		)
Property, equipment and capitalized software	(6,652		)	(2,308		)
Equity debt discount	(11,014		)	—
Goodwill and other intangible asset amortization	(199,964		)	(190,638		)
Total deferred tax liabilities	(222,717		)	(200,173		)
Foreign withholding tax	(413		)	(1,035		)
Valuation allowance	(21,929		)	(21,621		)
Net deferred tax liabilities	$	(150,109	)	$	(118,265	)

As of December 31, 2018 and 2017, the Company believes certain deferred tax assets principally associated with foreign tax credit, capital loss and foreign net operating loss carryforwards, which can be carried forward for periods ranging from 5 years to indefinite, will expire based on updated forward-looking financial information. Therefore, valuation allowances of $21.9 million and $21.6 million are recorded against the Company’s net deferred tax assets as of December 31, 2018 and 2017, respectively.

Prior to the passage of the 2017 Tax Act, the Company asserted that substantially all of the undistributed earnings of our foreign subsidiaries were considered indefinitely reinvested and accordingly, no deferred taxes were recognized. Pursuant to the provisions of the U.S. Tax Act, these earnings were subjected to U.S. federal taxation as a result of the one-time Transition Tax; however, these earnings may still be subject to foreign withholding taxes upon distribution. We have re-evaluated our historical assertion as a result of the 2017 Tax Act and determined that we no longer consider a majority of the undistributed earnings of our foreign subsidiaries to be indefinitely reinvested. As of December 31, 2018, the Company has recognized a deferred tax liability of $0.4 million for foreign withholding tax on undistributed earnings of our foreign subsidiaries that are not indefinitely reinvested.

As of December 31, 2018, the Company has not recorded a $17.8 million deferred tax liability related to the basis difference in the investment in our foreign subsidiaries, as the investment is considered permanent in nature.

The table below summarizes the components of income before income tax provision (benefit) from continuing operations.



	Year Ended December 31,
	2018		2017		2016
Domestic	$	96,543	$	30,013	$	66,202
Foreign	111,249		57,092		61,601
Total	$	207,792	$	87,105	$	127,803

The table below summarizes the components of income tax provision (benefit) from continuing operations.



	Year Ended December 31,
	2018		2017			2016
Current
Federal	$	10,847	$	15,164		$	(3,326	)
State	4,447		742			1,686
Foreign	21,056		14,816			13,864
	36,350		30,722			12,224
Deferred
Federal	14,538		(47,820		)	23,182
State	503		(152		)	8,284
Foreign	5,790		(3,607		)	(1,407		)
	20,831		(51,579		)	30,059
Income tax provision (benefit)	$	57,181	$	(20,857	)	$	42,283

Our income tax provision (benefit) from continuing operations resulted in effective tax rates that varied from the statutory federal income tax rate as summarized below.



	Year Ended December 31,
	2018			2017			2016
Income tax expense at federal statutory rate	$	43,636		$	30,487		$	44,731
State income taxes, net of federal benefit	4,950			781			6,075
Detriment (benefit) from lower foreign tax rates	3,655			(8,500		)	(7,827		)
Valuation allowance on foreign net operating loss carryforward	(450		)	253			254
Other expenses not deductible for tax purposes	3,543			2,466			3,082
Adjustment to reserve for uncertain tax positions	(132		)	456			(3,547		)
Impact of 2017 U.S. tax reform — deferred tax	(706		)	(63,525		)	—
Impact of 2017 U.S. tax reform — Transition Tax	50			18,655			—
Sale of Ringtail business	3,798			—			—
Other adjustments, net	(1,163		)	(1,930		)	(485		)
Income tax provision (benefit)	$	57,181		$	(20,857	)	$	42,283

The income tax expense for 2018 was $57.2 million, as compared with an income tax benefit of $20.9 million in 2017. The increase in expense is primarily attributable to higher pre-tax income in 2018 as compared with 2017 and the impact of the discrete income tax benefit of $44.9 million recorded in 2017 in connection with accounting for tax effects related to the 2017 Tax Act.

We file numerous consolidated and separate income tax returns in the U.S. federal jurisdiction and in many city, state and foreign jurisdictions. We are no longer subject to U.S. federal income tax examinations for years prior to 2014. We are also no longer subject to state and local or foreign tax examinations by tax authorities for years prior to 2012.

Our liability for uncertain tax positions was $3.7 million and $2.7 million as of December 31, 2018 and 2017, respectively. The Company does not expect any of the uncertain tax positions to settle within the next 12 months. As of December 31, 2018, our accrual for the payment of tax-related interest and penalties was not significant.