v3.10.0.1

Income Taxes (Tables) | 12 Months Ended
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Dec. 31, 2018
Income Tax Disclosure [Abstract] |
Schedule of Domestic and Foreign Components of Loss from Continuing Operations before Income Taxes | The components of our earnings (loss) from continuing operations before income taxes are as follows:
| Year ended December 31,
| 2018 |  | 2017 |  | 2016
| in millions
Belgium | $ | 392.4 |  |  | $ | 140.0 |  |  | $ | 13.7 |
U.K. | 330.9 |  |  | (991.3 | ) |  | 1,165.4 |
The Netherlands | (321.1 | ) | — |  | (26.1 | ) | — |  | 169.6 |
Switzerland | 318.8 |  |  | 111.6 |  |  | 273.9 |
U.S. | (51.6 | ) |  | (842.5 | ) |  | (873.0 | )
Intercompany activity with discontinued operations | (426.4 | ) |  | (499.9 | ) |  | (480.3 | )
Other | (81.2 | ) |  | (2.9 | ) |  | (26.0 | )
Total | $ | 161.8 |  |  | $ | (2,111.1 | ) |  | $ | 243.3 |
Schedule Of Income Tax Expense Benefit | Income tax benefit (expense) consists of:
| Current |  | Deferred |  | Total
| in millions
Year ended December 31, 2018: |  |  |  |  |
U.S. (a) | $ | (957.5 | ) |  | $ | 7.6 |  |  | $ | (949.9 | )
The Netherlands | 14.2 |  |  | (519.4 | ) |  | (505.2 | )
Belgium | (153.9 | ) |  | 41.6 |  |  | (112.3 | )
U.K. | (7.2 | ) |  | 32.2 |  |  | 25.0 |
Switzerland | (16.6 | ) |  | 6.2 |  |  | (10.4 | )
Other | (14.2 | ) |  | (6.3 | ) |  | (20.5 | )
Total | $ | (1,135.2 | ) |  | $ | (438.1 | ) |  | $ | (1,573.3 | )
Year ended December 31, 2017: |  |  |  |  |
The Netherlands | $ | (16.2 | ) |  | $ | (118.2 | ) |  | $ | (134.4 | )
U.K | (3.3 | ) |  | (64.7 | ) |  | (68.0 | )
Belgium | (203.6 | ) |  | 145.4 |  |  | (58.2 | )
U.S. (a) | 47.2 |  |  | (32.8 | ) |  | 14.4 |
Switzerland | (2.0 | ) |  | 15.6 |  |  | 13.6 |
Other | (14.4 | ) |  | 8.1 |  |  | (6.3 | )
Total | $ | (192.3 | ) |  | $ | (46.6 | ) |  | $ | (238.9 | )
Year ended December 31, 2016: |  |  |  |  |
The Netherlands | $ | (0.3 | ) |  | $ | 1,259.6 |  |  | $ | 1,259.3 |
U.S. (a) | 146.8 |  |  | 90.2 |  |  | 237.0 |
Belgium | (105.0 | ) |  | 57.0 |  |  | (48.0 | )
Switzerland | (48.4 | ) |  | 5.3 |  |  | (43.1 | )
U.K | (12.3 | ) |  | 1.2 |  |  | (11.1 | )
Other | (2.2 | ) |  | 15.1 |  |  | 12.9 |
Total | $ | (21.4 | ) |  | $ | 1,428.4 |  |  | $ | 1,407.0 |
_______________ (a) Includes federal and state income taxes. Our U.S. state income taxes were not material during any of the years presented.
Income Tax Benefit (Expense) Reconciliation | Income tax benefit (expense) attributable to our earnings (loss) from continuing operations before income taxes differs from the amounts computed using the applicable income tax rate as a result of the following factors:
| Year ended December 31,
| 2018 |  | 2017 |  | 2016
| in millions
Computed “expected” tax benefit (expense) (a) | $ | (30.7 | ) |  | $ | 406.4 |  |  | $ | (48.7 | )
Mandatory Repatriation Tax (b) | (1,137.2 | ) |  | — |  |  | — |
Basis and other differences in the treatment of items associated with investments in subsidiaries and affiliates (c) | (360.1 | ) |  | (192.6 | ) |  | (1.3 | )
Non-deductible or non-taxable interest and other expenses | (153.8 | ) |  | (42.8 | ) |  | 28.0 |
Non-deductible or non-taxable foreign currency exchange results | 132.5 |  |  | (233.8 | ) |  | 192.9 |
Recognition of previously unrecognized tax benefits | 49.6 |  |  | 4.9 |  |  | 210.9 |
Change in valuation allowances | (34.9 | ) |  | (341.6 | ) |  | 778.1 |
Enacted tax law and rate changes (d) | (13.5 | ) |  | 7.4 |  |  | (132.2 | )
International rate differences (e) | (3.5 | ) |  | 126.9 |  |  | 138.8 |
Tax benefit associated with technologies innovation | — |  |  | 12.1 |  |  | 72.6 |
Tax effect of intercompany financing | — |  |  | 2.4 |  |  | 161.6 |
Other, net | (21.7 | ) |  | 11.8 |  |  | 6.3 |
Total income tax benefit (expense) | $ | (1,573.3 | ) |  | $ | (238.9 | ) |  | $ | 1,407.0 |
_______________
(a) | The statutory or “expected” tax rates are the U.K. rates of 19% for 2018, 19.25% for 2017 and 20.00% for 2016. The 2017 statutory rate represents the blended rate that was in effect for the year ended December 31, 2017 based on the 20.0% statutory rate that was in effect for the first quarter of 2017 and the 19.0% statutory rate that was in effect for the remainder of 2017.
(b) | As further discussed below, the liability we have recorded for the Mandatory Repatriation Tax (as defined and described below) is significantly lower than the amount included in our income tax expense due in part to the expected use of carryforward attributes in the U.S., all of which were subject to valuation allowances prior to the initial recognition of the Mandatory Repatriation Tax during the first quarter of 2018.
(c) | These amounts reflect the net impact of differences in the treatment of income and loss items between financial reporting and tax accounting related to investments in subsidiaries and affiliates including the effects of foreign earnings.
(d) | On December 18, 2018, reductions in the corporate income tax rate in the Netherlands were enacted. The rate will be reduced from the current rate of 25.0% to 22.5% in 2020 and 20.5% in 2021. Substantially all of the impacts of these rate changes in the Netherlands on our deferred tax balances were recorded during the fourth quarter of 2018. In 2017, a Belgian income tax rate reduction was signed into law. The Belgian statutory tax rate decreased from 33.9% to 29.58% beginning in 2018, and in 2020, this rate will further decrease to 25.0%. Also in 2017, the U.S. corporate income tax rate was reduced from 35.0% to 21.0% effective beginning in 2018. Substantially all of the impacts of the tax rate changes in Belgium and the U.S. on our deferred tax balances were recorded during the fourth quarter of 2017. During the third quarter of 2016, the U.K. enacted legislation that will reduce the corporate income tax rate in April 2020 to 17.0%. Substantially all of the impact of this rate change on our deferred tax balances was recorded during the third quarter of 2016.
(e) | Amounts reflect adjustments (either a benefit or expense) to the “expected” tax benefit (expense) for statutory rates in jurisdictions in which we operate outside of the U.K.
Schedule Of Current And Noncurrent Deferred Tax Assets And Liabilities | The components of our net deferred tax assets are as follows:
| December 31,
| 2018 |  | 2017
| in millions
Deferred tax assets | $ | 2,488.2 |  |  | $ | 3,133.1 |
Deferred tax liabilities (a) | (232.9 | ) |  | (225.5 | )
Net deferred tax asset | $ | 2,255.3 |  |  | $ | 2,907.6 |
_______________
(a) | Our deferred tax liabilities are included in other long-term liabilities in our consolidated balance sheets.
The tax effects of temporary differences that give rise to significant portions of the deferred tax assets and deferred tax liabilities are presented below:
| December 31,
| 2018 |  | 2017
| in millions
Deferred tax assets: |  |  |
Net operating loss and other carryforwards | $ | 4,289.8 |  |  | $ | 5,074.2 |
Property and equipment, net | 1,923.4 |  |  | 2,064.2 |
Debt | 322.9 |  |  | 544.1 |
Investments | 156.2 |  |  | 97.0 |
Share-based compensation | 79.5 |  |  | 71.7 |
Derivative instruments | 72.5 |  |  | 155.8 |
Intangible assets | 14.8 |  |  | 44.7 |
Other future deductible amounts | 161.3 |  |  | 87.2 |
Deferred tax assets | 7,020.4 |  |  | 8,138.9 |
Valuation allowance | (4,094.7 | ) |  | (4,244.7 | )
Deferred tax assets, net of valuation allowance | 2,925.7 |  |  | 3,894.2 |
Deferred tax liabilities: |  |  |
Intangible assets | (193.8 | ) |  | (298.3 | )
Deferred revenue | (178.9 | ) |  | (229.8 | )
Property and equipment, net | (167.4 | ) |  | (212.4 | )
Investments (including consolidated partnerships) | (0.8 | ) |  | (130.3 | )
Other future taxable amounts | (129.5 | ) |  | (115.8 | )
Deferred tax liabilities | (670.4 | ) |  | (986.6 | )
Net deferred tax asset | $ | 2,255.3 |  |  | $ | 2,907.6 |
Summary of Operating Loss Carryforwards | The significant components of our tax loss carryforwards and related tax assets at December 31, 2018 are as follows:
Country |  | Tax loss carryforward |  | Related tax asset |  | Expiration date
| in millions |  |
U.K.: |  |  |  |  |
Amount attributable to capital losses | $ | 15,426.3 |  |  | $ | 2,622.5 |  |  | Indefinite
Amount attributable to net operating losses | 1,025.6 |  |  | 174.3 |  |  | Indefinite
The Netherlands | 3,923.1 |  |  | 842.5 |  |  | 2019-2027
Belgium | 1,288.9 |  |  | 324.1 |  |  | Indefinite
Ireland | 708.5 |  |  | 88.8 |  |  | Indefinite
France | 544.5 |  |  | 157.5 |  |  | Indefinite
U.S. | 382.3 |  |  | 16.8 |  |  | Various
Other | 245.6 |  |  | 63.3 |  |  | Various
Total | $ | 23,544.8 |  |  | $ | 4,289.8 |  |  |
Unrecognized Tax Benefits Roll Forward | The changes in our unrecognized tax benefits are summarized below:
| 2018 |  | 2017 |  | 2016
| in millions
Balance at January 1 | $ | 350.4 |  |  | $ | 217.0 |  |  | $ | 486.8 |
Additions for tax positions of prior years | 457.4 |  |  | 138.8 |  |  | 2.0 |
Additions based on tax positions related to the current year | 180.0 |  |  | 4.5 |  |  | 5.6 |
Reductions for tax positions of prior years | (117.9 | ) |  | (20.4 | ) |  | (183.5 | )
Foreign currency translation | (8.5 | ) |  | 14.1 |  |  | (2.1 | )
Lapse of statute of limitations | (3.6 | ) |  | — |  |  | (78.3 | )
Settlements with tax authorities | — |  |  | (3.6 | ) |  | (13.5 | )
Balance at December 31 | $ | 857.8 |  |  | $ | 350.4 |  |  | $ | 217.0 |

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