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Income Taxes
9 Months Ended
Sep. 30, 2020
Income Tax Disclosure [Abstract]  
Income Taxes INCOME TAXES
Income tax expense was $143 million and $233 million for the three and nine months ended September 30, 2020, respectively, compared to income tax expense of $313 million and $311 million in the same period of 2019. For the three months ended September 30, 2020, the decrease in tax expense from the prior period is due primarily to tax expense on the sale of Embraco, prior period adjustments, and impact of tax law changes in the prior period. For the nine months ended September 30, 2020, the decrease in tax expense from the prior period is due to tax expense on the sale of Embraco, prior period adjustments, partially offset by valuation allowance releases in the prior period.
The following table summarizes the difference between income tax expense (benefit) at the U.S. statutory rate of 21% and the income tax expense (benefit) at effective worldwide tax rates for the respective periods:
Three Months Ended September 30, Nine Months Ended September 30,
Millions of dollars2020201920202019
Earnings before income taxes$541 $677 $803 $1,221 
Income tax expense computed at United States statutory tax rate113 142 169 256 
Valuation allowances6 12 (195)
U.S. transition tax and prior period adjustments 56  56 
Audits and settlements14 31 (6)
U.S. foreign income items, net of credits(2)(1)19 
Changes in enacted tax rates(6)41 (6)66 
Sale of Embraco 43  54 
Other18 15 28 61 
Income tax expense (benefit) computed at effective worldwide tax rates$143 $313 $233 $311 
At the end of each interim period, we estimate the effective tax rate expected to be applicable for the full fiscal year and the impact of discrete items, if any, and adjust the quarterly rate as necessary.
Valuation Allowances
We routinely review the future realization of deferred tax assets based on projected future reversal of taxable temporary differences, available tax planning strategies and projected future taxable income. During the first quarter of 2019, we completed a $700 million bond offering for which the proceeds were used to refinance and recapitalize various entities in the EMEA region. Based upon existing transfer pricing policies, these actions are projected to provide sufficient future taxable income to realize the deferred tax assets. These actions injected additional internal capital into certain EMEA entities to meet local country capitalization requirements, as well as repaid all outstanding borrowings under the Whirlpool EMEA Finance Term Loan. As a result, we reduced the valuation allowance by $235 million during the first quarter of 2019.
Other Income Tax Matters
During its examination of Whirlpool’s 2009 U.S. federal income tax return, the IRS asserted that income earned by a Luxembourg subsidiary via its Mexican branch should be recognized as income on its 2009 U.S. federal income tax return. The Company believed the proposed assessment was without merit and contested the matter in United
States Tax Court (US Tax Court). Both Whirlpool and the IRS moved for partial summary judgment on this issue. On May 5, 2020, the US Tax Court granted the IRS’s motion for partial summary judgment and denied Whirlpool’s. The Company has appealed the US Tax Court decision to the United States Sixth Circuit Court of Appeals. The Company believes that it will be successful upon appeal and has not recorded any impact of the US Tax Court’s decision in its consolidated financial statements.