INCOME TAXES

Income before income taxes was taxed in the following jurisdictions in each of the years ended December 31:



	2014		2013		2012
	(Dollars in thousands)
Domestic	$	273,487	$	252,961	$	212,213
Foreign	11,065		1,757		11,574
Total	$	284,552	$	254,718	$	223,787

The components of the provision for income taxes were as follows:



	2014			2013			2012
	(Dollars in thousands)
Current:
Federal	$	51,399		$	48,905		$	57,106
State	4,487			5,954			8,449
Foreign	7,519			7,321			8,385
Current income tax provision	63,405			62,180			73,940
Deferred:
Federal	38,879			9,559			5,999
State	2,958			2,637			(610		)
Foreign	(3,081		)	(5,071		)	(6,888		)
Deferred income tax provision (benefit)	38,756			7,125			(1,499		)
	$	102,161		$	69,305		$	72,441

The provision for income taxes varied from income taxes computed at the statutory U.S. federal income tax rate as a result of the following:



	2014			2013			2012
	(Dollars in thousands)
Income taxes computed at the statutory U.S. federal income tax rate	$	99,597		$	89,151		$	78,325
State income taxes, net of federal tax benefit	8,165			7,775			5,978
Tax liabilities required (no longer required)	815			(17,043		)	(182		)
Valuation allowance	(3,747		)	(5,087		)	239
Manufacturing exemption	(5,798		)	(7,452		)	(6,865		)
Tax credit refunds, net	(2,163		)	(1,797		)	(1,066		)
Foreign earnings taxed at other than 35%	5,957			(600		)	(566		)
Deferred tax rate changes	(1,327		)	2,235			(3,422		)
Other	662			2,123			—
	$	102,161		$	69,305		$	72,441

Effective tax rate	35.9		%	27.2		%	32.4		%

Deferred income taxes reflect the net tax effect of temporary differences between the financial statement carrying amounts of assets and liabilities and their respective tax bases and operating loss and tax credit carryforwards. Significant components of our deferred tax assets and liabilities at December 31 were as follows:



	2014			2013
	(Dollars in thousands)
Deferred tax assets:
Pension and other postretirement liabilities	$	14,957		$	9,805
Rationalization and other accrued liabilities	14,933			26,031
Property, Plant and Equipment	1,182			—
AMT and other credit carryforwards	1,500			2,400
Net operating loss carryforwards	33,972			42,176
Foreign currency translation	825			2,076
Inventory and related reserves	7,327			7,722
Other	9,952			7,202
Total deferred tax assets	84,648			97,412
Deferred tax liabilities:
Property, plant and equipment	(194,793		)	(200,359		)
Pension and other post retirement liabilities	(13,383		)	(28,552		)
Other intangible assets	(80,552		)	(49,114		)
Foreign currency translation	(13,110		)	(4,206		)
Other	(3,988		)	(12,369		)
Total deferred tax liabilities	(305,826		)	(294,600		)
Valuation allowance	(7,858		)	(11,704		)
	$	(229,036	)	$	(208,892	)

At December 31, 2014, the net deferred tax liability in our Consolidated Balance Sheets was comprised of current deferred tax assets of $22.4 million, long-term deferred tax assets of $19.9 million and long-term deferred tax liabilities of $271.3 million. At December 31, 2013, the net deferred tax liability in our Consolidated Balance Sheets was comprised of current deferred tax assets of $23.7 million, long-term deferred tax assets of $19.6 million and long-term deferred tax liabilities of $252.2 million. Current deferred tax assets, long-term deferred tax assets and long-term deferred tax liabilities were classified as prepaid expenses and other current assets, other assets, net and other liabilities, respectively, in our Consolidated Balance Sheets.

During 2013, we acquired Portola. A portion of the purchase price for Portola was allocated to goodwill and other intangible assets, which are not tax deductible in the applicable jurisdictions. During 2012, we acquired PFC. A portion of the purchase price for PFC was allocated to goodwill and other intangible assets, which are tax deductible in the applicable jurisdictions and are being amortized over 15 years for tax purposes.

The valuation allowance in 2014 includes deferred tax assets of $7.9 million resulting from foreign net operating loss carryforwards, or NOLs. The valuation allowance for deferred tax assets decreased in 2014 by $3.8 million primarily due to a decrease in the valuation allowance related to foreign tax loss carryforwards and state and local tax credits. Silgan has federal NOLs of approximately $3.7 million related to the acquisition of Portola that will expire in 2033.

At December 31, 2014, we had foreign NOLs of approximately $24.7 million that are available to offset future taxable income. Of that amount, approximately $12.2 million will expire from 2015 to 2025. The remaining portion has no expiration date. At December 31, 2014, we had state tax NOLs of approximately $5.5 million that are available to offset future taxable income and that will expire from 2015 to 2032.

We recognize accrued interest and penalties related to unrecognized taxes as additional income tax expense. At December 31, 2014 and 2013, we had $3.4 million and $2.8 million, respectively, accrued for potential interest and penalties.

The total amount of unrecognized tax benefits recorded in other liabilities as of December 31, 2014 and 2013 were $27.8 million and $26.7 million, respectively, excluding associated tax assets and including the federal tax benefit of state taxes, interest and penalties.

Tax assets associated with uncertain tax positions primarily represent our estimate of the potential tax benefits in one tax jurisdiction that could result from the payment of income taxes in another jurisdiction. At December 31, 2014 and 2013, we had approximately $16.1 million and $15.9 million, respectively, in assets associated with uncertain tax positions recorded in other assets in our Consolidated Balance Sheets.

A reconciliation of the beginning and ending amount of gross unrecognized tax benefits included as other liabilities in our Consolidated Balance Sheets was as follows:



	2014			2013
	(Dollars in thousands)
Balance at January 1,	$	50,398		$	51,433
Increase based upon tax positions of current year	646			535
Increase based upon tax positions of a prior year	457			139
(Decrease) increase due to acquisitions	(2,732		)	27,086
Decrease based upon settlements with taxing authorities	(50		)	(28,346		)
Decrease based upon a lapse in the statute of limitations	(576		)	(449		)
Balance at December 31,	$	48,143		$	50,398

The total amount of unrecognized tax benefits that would impact the effective tax rate, if recognized, at December 31, 2014 and 2013 were $11.8 million and $11.6 million, respectively.

Silgan and its subsidiaries file U.S. Federal income tax returns, as well as income tax returns in various states and foreign jurisdictions. The Internal Revenue Service, or IRS, concluded its review of tax years through 2011, resulting in the recognition of previously gross unrecognized tax benefits of $28.3 million. We recorded a $20.5 million benefit to the effective tax rate for 2013 primarily related to this settlement and associated payments. The unrecognized tax benefits included items predating the years under audit as a result of the NOLs utilized during the period and items arising in the audit period. These items, primarily related to the timing and character of losses arising from the write-off of intercompany obligations and instruments, were covered by the terms of closing agreements with the IRS. The IRS has commenced its review of the tax years 2012 through 2014, and we have been accepted into the Compliance Assurance Program for the 2014 and 2015 tax years which provides for the review by the IRS of tax matters relating to our tax return prior to filing. We are subject to examination by state and local tax authorities generally for the period mandated by statute, with the exception of states where waivers of the statute of limitations have been executed. These states and the earliest open period include Wisconsin (1995), Nebraska (2006) and Indiana (2007). Our foreign subsidiaries are generally not subject to examination by tax authorities for periods before 2008, and we have contractual indemnities with third parties with respect to open periods that predate our ownership of certain foreign subsidiaries. Subsequent periods may be examined by the relevant tax authorities. We do not expect a material change to our unrecognized tax benefits within the next twelve months.

We had undistributed earnings from foreign subsidiaries of $74.3 million at December 31, 2014. If the earnings of foreign subsidiaries were not indefinitely reinvested, a deferred tax liability of $26.0 million would be required, excluding the potential use of foreign tax credits in the United States.