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Income taxes | 12 Months Ended
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Dec. 31, 2023
Income Tax Disclosure [Abstract] |
Income taxes | Income taxes The provision for taxes on income for the years ended December 31 consists of the following:
| 2023 |  | 2022 |  | 2021
Pretax income |  |  |  |  |
Domestic | $ | 400,241 |  |  | $ | 363,518 |  |  | $ | (342,951) |
Foreign | 214,591 |  |  | 207,764 |  |  | 181,969 |
Total pretax income | $ | 614,832 |  |  | $ | 571,282 |  |  | $ | (160,982) |
Current |  |  |  |  |
Federal | $ | 79,200 |  |  | $ | 55,016 |  |  | $ | 21,247 |
State | 16,681 |  |  | 15,997 |  |  | 15,212 |
Foreign | 65,617 |  |  | 59,762 |  |  | 55,018 |
Total current | $ | 161,498 |  |  | $ | 130,775 |  |  | $ | 91,477 |
Deferred |  |  |  |  |
Federal | $ | (5,447) |  |  | $ | (2,495) |  |  | $ | (120,243) |
State | (2,249) |  |  | (5,441) |  |  | (39,709) |
Foreign | (4,524) |  |  | (4,330) |  |  | 1,045 |
Total deferred | $ | (12,220) |  |  | $ | (12,266) |  |  | $ | (158,907) |
Total taxes | $ | 149,278 |  |  | $ | 118,509 |  |  | $ | (67,430) |
Deferred tax (liabilities)/assets are comprised of the following at December 31:
| 2023 |  | 2022
Property, plant and equipment | $ | (137,880) |  |  | $ | (104,162) |
Intangibles | (119,225) |  |  | (104,171) |
Leases | (48,832) |  |  | (89,226) |
Outside basis in Metal Packaging | (68,867) |  |  | (74,092) |
Gross deferred tax liabilities | $ | (374,804) |  |  | $ | (371,651) |
Retiree health benefits | $ | 513 |  |  | $ | 1,222 |
Foreign loss carryforwards | 62,250 |  |  | 79,460 |
U.S. Federal loss and credit carryforwards | 39,131 |  |  | 36,529 |
Capital loss carryforwards | 3,817 |  |  | 3,626 |
U.S. State loss and credit carryforwards | 21,321 |  |  | 20,961 |
Capitalized research and development costs | 87,743 |  |  | 45,826 |
Employee benefits | 51,829 |  |  | 42,641 |
Leases | 50,704 |  |  | 89,416 |
Accrued liabilities and other assets | 58,699 |  |  | 56,601 |
Gross deferred tax assets | $ | 376,007 |  |  | $ | 376,282 |
Valuation allowance on deferred tax assets | $ | (70,661) |  |  | $ | (82,046) |
Total deferred taxes, net | $ | (69,458) |  |  | $ | (77,415) |
The Company has total federal net operating loss carryforwards of approximately $79,501 remaining at December 31, 2023. These losses are limited based upon future taxable earnings of the Company and expire between 2032 and 2038. U.S. foreign tax credit carryforwards of approximately $22,434 exist at December 31, 2023 and expire in 2027. Foreign subsidiary loss carryforwards of approximately $258,412 remain at December 31, 2023. Their use is limited to future taxable earnings of the respective foreign subsidiaries or filing groups. Approximately $203,574 of these loss carryforwards do not have an expiration date. Of the remaining foreign subsidiary loss carryforwards, approximately $15,178 expire within the next five years and approximately $39,660 expire between 2029 and 2043. Foreign subsidiary capital loss carryforwards of approximately $15,256 exist at December 31, 2023 and do not have an expiration date. Their use is limited to future capital gains of the respective foreign subsidiaries. Approximately $10,113 in tax value of state loss carryforwards and $16,876 of state credit carryforwards remain at December 31, 2023. These state loss and credit carryforwards are limited based upon future taxable earnings of the respective entities or filing group and expire between 2024 and 2044. State loss and credit carryforwards are reflected at their “tax” value, as opposed to the amount of expected gross deduction due to the vastly different apportionment and statutory tax rates applicable to the various entities and states in which the Company files. A reconciliation of the U.S. federal statutory tax rate to the actual provision for/(benefit from) income taxes is as follows:
| 2023 |  | 2022 |  | 2021
Statutory tax rate | $ | 129,115 |  |  | 21.0 | % |  | $ | 119,945 |  |  | 21.0 | % |  | $ | (33,806) |  |  | 21.0 | %
State income taxes, net of federal tax benefit | 16,051 |  |  | 2.6 | % |  | 13,149 |  |  | 2.3 | % |  | (15,863) |  |  | 9.9 | %
Valuation allowance | 4,486 |  |  | 0.7 | % |  | (10,477) |  |  | (1.8) | % |  | (33,576) |  |  | 20.9 | %
Tax examinations including change in reserve for uncertain tax positions | 2,183 |  |  | 0.4 | % |  | 567 |  |  | 0.1 | % |  | 5,665 |  |  | (3.5) | %
Adjustments to prior year deferred taxes | (2,489) |  |  | (0.4) | % |  | (2,110) |  |  | (0.4) | % |  | 1,239 |  |  | (0.8) | %
Foreign earnings taxed at other than U.S. rates | 13,704 |  |  | 2.2 | % |  | 12,334 |  |  | 2.2 | % |  | 9,659 |  |  | (6.0) | %
Divestiture of business | 464 |  |  | 0.1 | % |  | — |  |  | — | % |  | (808) |  |  | 0.5 | %
Effect of tax rate changes | 387 |  |  | 0.1 | % |  | (2,151) |  |  | (0.4) | % |  | 275 |  |  | (0.2) | %
Foreign withholding taxes | 4,635 |  |  | 0.8 | % |  | 4,670 |  |  | 0.8 | % |  | 8,107 |  |  | (5.0) | %
Tax credits | (18,841) |  |  | (3.1) | % |  | (14,077) |  |  | (2.5) | % |  | (21,936) |  |  | 13.6 | %
Global intangible low-taxed income (GILTI) | 2,930 |  |  | 0.5 | % |  | 2,851 |  |  | 0.5 | % |  | 11,323 |  |  | (7.0) | %
Foreign-derived intangible income | (1,106) |  |  | (0.2) | % |  | (657) |  |  | (0.1) | % |  | (202) |  |  | 0.1 | %
Foreign currency gain/(loss) on distributions of previously taxed income | (2,614) |  |  | (0.4) | % |  | (1,280) |  |  | (0.2) | % |  | 3,365 |  |  | (2.1) | %
Other, net | 373 |  |  | 0.1 | % |  | (4,255) |  |  | (0.7) | % |  | (872) |  |  | 0.5 | %
Provision for/(Benefit from) income taxes | $ | 149,278 |  |  | 24.3 | % |  | $ | 118,509 |  |  | 20.7 | % |  | $ | (67,430) |  |  | 41.9 | %
The Company was subject to the one-time transition tax on certain accumulated foreign earnings as part of the Tax Cuts and Jobs Act (“Tax Act”). Under the provisions of the Tax Act, the transition tax was payable in installments over a period of 8 years. The Company paid its final installment of $1,366 during 2023 and has no remaining obligation. The change in “Tax examinations including change in reserve for uncertain tax positions” is shown net of associated deferred taxes and accrued interest. Included in the change are net increases in reserves for uncertain tax positions of approximately $3,074, $2,051 and $2,330 for uncertain items arising in 2023, 2022 and 2021, respectively, combined with adjustments related to prior year items, primarily decreases related to lapses of statutes of limitations in international, federal and state jurisdictions as well as overall changes in facts and judgment. These adjustments changed the reserve by a total of approximately $(891), $(1,484) and $3,743 in 2023, 2022 and 2021, respectively. In many of the countries in which the Company operates, earnings are taxed at rates different than in the United States. This difference is reflected in “Foreign earnings taxed at other than U.S. rates” along with other items, if any, that impacted taxes on foreign earnings in the periods presented. The benefits included in “Adjustments to prior year deferred taxes” for each of the years presented consist primarily of adjustments to deferred tax assets and liabilities arising from changes in estimates. Of the $18,841 of tax credits for 2023, $2,442 directly offset the $2,930 of GILTI tax, resulting in a net GILTI tax of $488. Of the remainder, $8,735 relates to research and development tax credits. The GILTI tax in 2022 of $2,851 was partially offset by GILTI tax credits of $1,245, resulting in a net GILTI tax of $1,606. The benefits included in “Valuation allowance” for 2022 include a $13,182 net recognized benefit associated with the release of valuation allowance on foreign NOLs due to an increase in projected future foreign income. The Company maintains its assertion that its undistributed foreign earnings are indefinitely reinvested and, accordingly, has not recorded any deferred income tax liabilities that would be due if those earnings were repatriated. As of December 31, 2023, these undistributed earnings total $1,040,580. While the majority of these earnings have already been taxed in the United States, a portion would be subject to foreign withholding and U.S. income taxes and credits if distributed. Computation of the deferred tax liability associated with unremitted earnings deemed to be indefinitely reinvested is not practicable at this time. Reserve for uncertain tax positions The following table sets forth the reconciliation of the gross amounts of unrecognized tax benefits at the beginning and ending of the periods indicated:
| 2023 |  | 2022 |  | 2021
Gross Unrecognized Tax Benefits at January 1 | $ | 18,621 |  |  | $ | 18,142 |  |  | $ | 11,230 |
Increases in prior years’ unrecognized tax benefits | 378 |  |  | 223 |  |  | 12,283 |
Decreases in prior years’ unrecognized tax benefits | (572) |  |  | (144) |  |  | (275) |
Increases in current year’s unrecognized tax benefits | 4,395 |  |  | 1,807 |  |  | 1,088 |
Decreases in unrecognized tax benefits from the lapse of statutes of limitations | (1,094) |  |  | (1,174) |  |  | (6,170) |
Settlements | (51) |  |  | (233) |  |  | (14) |
Gross Unrecognized Tax Benefits at December 31 | $ | 21,677 |  |  | $ | 18,621 |  |  | $ | 18,142 |
Of the unrecognized tax benefit balances at December 31, 2023 and December 31, 2022, $19,241 and $17,821, respectively, would have an impact on the effective tax rate if ultimately recognized. Interest and/or penalties related to income taxes are reported as part of income tax expense. The Company had $1,773 and $859 accrued for interest related to uncertain tax positions at December 31, 2023 and December 31, 2022, respectively. Tax expense for the year ended December 31, 2023, includes net interest expense of $914, which is comprised of an interest benefit of $272 related to the adjustment of prior years’ items and interest expense of $1,186 on unrecognized tax benefits. The amounts listed above for accrued interest and interest expense do not reflect the benefit of a federal tax deduction which would be available if the interest were ultimately paid. The Company and/or its subsidiaries file federal, state and local income tax returns in the United States and various foreign jurisdictions. With few exceptions, the Company is no longer subject to income tax examinations by tax authorities for years before 2017. The Company believes that it is reasonably possible that the amount reserved for uncertain tax positions at December 31, 2023 will decrease by $10,018 over the next twelve months. This change includes the anticipated increase in reserves related to existing positions offset by settlements of issues currently under examination and the release of existing reserves due to the expiration of the statute of limitations. Although the Company’s estimate for the potential outcome for any uncertain tax issue is highly judgmental, management believes that any reasonably foreseeable outcomes related to these matters have been adequately provided for. However, future results may include favorable or unfavorable adjustments to estimated tax liabilities in the period the assessments are made or resolved or when statutes of limitation on potential assessments expire. Additionally, the jurisdictions in which earnings or deductions are realized may differ from current estimates. As a result, the effective tax rate may fluctuate significantly on a quarterly basis. The Company has operations in many countries outside of the United States and the taxes paid on those earnings are subject to varying rates. The Company is not dependent upon the favorable benefit of any one jurisdiction to an extent that loss of those benefits would have a material effect on the Company’s overall effective tax rate.

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- Definition The entire disclosure for income taxes. Disclosures may include net deferred tax liability or asset recognized in an enterprise's statement of financial position, net change during the year in the total valuation allowance, approximate tax effect of each type of temporary difference and carryforward that gives rise to a significant portion of deferred tax liabilities and deferred tax assets, utilization of a tax carryback, and tax uncertainties information. + References Reference 1: http://www.xbrl.org/2003/role/disclosureRef -Topic 946 -SubTopic 20 -Name Accounting Standards Codification -Section 50 -Paragraph 13 -Publisher FASB -URI https://asc.fasb.org//1943274/2147480990/946-20-50-13 Reference 2: http://www.xbrl.org/2003/role/disclosureRef -Topic 235 -SubTopic 10 -Name Accounting Standards Codification -Section S99 -Paragraph 1 -Subparagraph (SX 210.4-08(h)(2)) -Publisher FASB -URI https://asc.fasb.org//1943274/2147480678/235-10-S99-1 Reference 3: http://www.xbrl.org/2003/role/disclosureRef -Topic 740 -Name Accounting Standards Codification -Publisher FASB -URI https://asc.fasb.org//740/tableOfContent Reference 4: http://www.xbrl.org/2003/role/disclosureRef -Topic 740 -SubTopic 10 -Name Accounting Standards Codification -Section 50 -Paragraph 14 -Publisher FASB -URI https://asc.fasb.org//1943274/2147482685/740-10-50-14 Reference 5: http://www.xbrl.org/2003/role/disclosureRef -Topic 740 -SubTopic 10 -Name Accounting Standards Codification -Section 50 -Paragraph 21 -Publisher FASB -URI https://asc.fasb.org//1943274/2147482685/740-10-50-21 Reference 6: http://www.xbrl.org/2003/role/disclosureRef -Topic 740 -SubTopic 270 -Name Accounting Standards Codification -Section 50 -Paragraph 1 -Publisher FASB -URI https://asc.fasb.org//1943274/2147482526/740-270-50-1 Reference 7: http://www.xbrl.org/2003/role/disclosureRef -Topic 740 -SubTopic 10 -Name Accounting Standards Codification -Section 50 -Paragraph 17 -Subparagraph (b) -Publisher FASB -URI https://asc.fasb.org//1943274/2147482685/740-10-50-17 Reference 8: http://www.xbrl.org/2003/role/disclosureRef -Topic 740 -SubTopic 10 -Name Accounting Standards Codification -Section S99 -Paragraph 1 -Subparagraph (SAB TOPIC 6.I.5.Q1) -Publisher FASB -URI https://asc.fasb.org//1943274/2147479360/740-10-S99-1 Reference 9: http://www.xbrl.org/2003/role/disclosureRef -Topic 740 -SubTopic 10 -Name Accounting Standards Codification -Section S99 -Paragraph 2 -Subparagraph (SAB Topic 11.C) -Publisher FASB -URI https://asc.fasb.org//1943274/2147479360/740-10-S99-2 Reference 10: http://www.xbrl.org/2003/role/disclosureRef -Topic 740 -SubTopic 30 -Name Accounting Standards Codification -Section 50 -Paragraph 2 -Subparagraph (a) -Publisher FASB -URI https://asc.fasb.org//1943274/2147482603/740-30-50-2 + Details
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