XML 72 R49.htm IDEA: XBRL DOCUMENT v3.25.0.1
Income Taxes (Tables)
12 Months Ended
Dec. 31, 2024
Income Tax Disclosure [Abstract]  
Schedule of Income Before Income Tax, Domestic and Foreign
Domestic and foreign components of income (loss) from continuing operations before income taxes are shown below: 
 Year Ended December 31,
(in Millions)202420232022
Domestic$(271.6)$(312.7)$(89.6)
Foreign524.1 612.9 1,073.5 
Total$252.5 $300.2 $983.9 
Schedule of Components Of Income Tax Expense (Benefit)
The provision (benefit) for income taxes attributable to income (loss) from continuing operations consisted of: 
 Year Ended December 31,
(in Millions)202420232022
Current:
Federal$28.2 $58.5 $45.7 
Foreign160.2 113.9 152.1 
State1.0 1.1 0.1 
Total current$189.4 $173.5 $197.9 
Deferred:
Federal$(66.0)$(82.7)$(28.6)
Foreign(271.9)(1,212.0)(27.4)
State(2.4)1.9 3.3 
Total deferred$(340.3)$(1,292.8)$(52.7)
Total$(150.9)$(1,119.3)$145.2 
Schedule of Effective Income Tax Rate Reconciliation
The effective income tax rate applicable to income from continuing operations before income taxes was different from the statutory U.S. federal income tax rate due to the factors listed in the following table: 
 Year Ended December 31,
(in Millions)202420232022
U.S. Federal statutory rate$53.0 $63.0 $206.6 
Foreign earnings subject to different tax rates (1)
(137.3)(130.7)(152.7)
State and local income taxes, less federal income tax benefit(7.7)2.5 5.5 
Research and development and miscellaneous tax credits(5.7)(5.4)(5.7)
Tax on dividends, deemed dividends, and GILTI (2)
41.9 37.0 24.6 
Changes to unrecognized tax benefits9.6 10.5 10.5 
Nondeductible expenses9.3 9.3 19.6 
Change in valuation allowance (3)
639.7 172.5 71.3 
Exchange gains and losses (4)
30.3 (18.4)(12.0)
Impact of Switzerland tax incentives (5)
(645.0)(1,149.2)— 
Other (6)
(139.0)(110.4)(22.5)
Total Tax Provision$(150.9)$(1,119.3)$145.2 
___________________________
(1)A significant amount of our earnings is generated by our foreign subsidiaries (e.g., Switzerland, Singapore, Hong Kong), which tax earnings at lower statutory rates than the United States federal statutory rate. Our future effective tax rates may be materially impacted by a future change in the composition of earnings from foreign and domestic tax jurisdictions.
(2)The years ended December 31, 2024, 2023, and 2022 includes tax expense of $18.1 million, $25.5 million, and $17.8 million, respectively, associated with the global intangible low-taxed income (GILTI) provisions.
(3)The year ended December 31, 2024 is primarily related to the estimated portion of nonrefundable tax credits within our Swiss operations that are not expected to be utilized, the impact of the step-up in tax basis to the fair value of the transferred intellectual property by the Company’s Swiss subsidiary, and net operating losses within our full valuation allowance Luxembourg operations. The year ended December 31, 2023 is primarily related to the estimated portion of nonrefundable tax credits within our Swiss operations that are not expected to be utilized and net operating losses and other deferred tax assets within our Argentina operations, partially offset by the release of the valuation allowance within our Brazil operations, as described further below. The year ended December 31, 2022 is primarily related to net operating losses and other deferred tax assets within our Brazil and Argentina operations.
(4)Includes the impact of transaction gains or losses on net monetary assets for which no corresponding tax expense or benefit is realized and the tax provision for statutory taxable gains or losses in foreign jurisdictions for which there is no corresponding amount in income before taxes.
(5)The year ended December 31, 2024 represents the recognition of a step-up in tax basis to the fair value of the transferred intellectual property by the Company's Swiss subsidiary. The year ended December 31, 2023 is related to ten-year nonrefundable tax credits granted to the Company's Swiss subsidiaries, as discussed above.
(6)The year ended December 31, 2024 includes a U.S. capital loss in the amount of $38.6 million and additional amounts materially attributable to internal restructuring in our full valuation allowance Luxembourg entities. The year ended December 31, 2023 includes a net decrease of approximately $120 million related to adjustments of deferred tax balances in Singapore, Puerto Rico, and Switzerland. The year ended December 31, 2022 included a $39.7 million decrease related to certain deferred tax liabilities as a result of the extension of our incentive tax rate in Puerto Rico.
Schedule of Deferred Tax Assets and Liabilities
Significant components of our deferred tax assets and liabilities were attributable to:
 December 31,
(in Millions)20242023
Reserves for discontinued operations, environmental and restructuring$190.1 $144.7 
Accrued pension and other postretirement benefits5.3 9.8 
Capital loss, foreign tax and other credit carryforwards1,128.1 1,136.0 
Net operating loss carryforwards564.1 411.2 
Deferred expenditures capitalized for tax108.6 94.5 
Intangibles, Property, plant and equipment, and Investments, net387.9 — 
Other accruals and reserves267.5 234.0 
Deferred tax assets$2,651.6 $2,030.2 
Valuation allowance, net(1,213.8)(588.4)
Deferred tax assets, net of valuation allowance$1,437.8 $1,441.8 
Intangibles, Property, plant and equipment, and Investments, net— 263.3 
Deferred tax liabilities$ $263.3 
Net deferred tax assets (liabilities)$1,437.8 $1,178.5 
Schedule of Unrecognized Tax Benefits
A reconciliation of the beginning and ending amount of unrecognized tax benefits is as follows: 
December 31,
(in Millions)202420232022
Balance at beginning of year$51.2 $46.1 $41.9 
Increases related to positions taken in the current year8.6 2.4 4.8 
Increases and decreases related to positions taken in prior years(1.2)3.5 2.9 
Decreases related to lapse of statutes of limitations(5.5)(0.8)(3.5)
Settlements during the current year— — — 
Decreases for tax positions on dispositions— — — 
Balance at end of year (1)
$53.1 $51.2 $46.1 
___________________________
(1)At December 31, 2024, 2023, and 2022 we recognized an offsetting non-current asset of $10.5 million, $12.9 million, and $12.8 million respectively, relating to the indirect income tax benefits associated with specific uncertain tax positions presented above.