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Income Taxes (Tables)

12 Months Ended

Dec. 31, 2019

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,
	2019					2018					2017
	in millions
U.K.	$	(831.0	)			$	330.9				$	(991.3	)
The Netherlands	(662.8		)	—		(321.1		)	—		(26.1		)
Belgium	409.3					392.4					140.0
Switzerland	178.5					318.8					111.6
U.S.	(7.0		)			(51.6		)			(842.5		)
Intercompany activity with discontinued operations	(237.2		)			(426.4		)			(499.9		)
Other	(5.8		)			(81.2		)			(2.9		)
Total	$	(1,156.0	)			$	161.8				$	(2,111.1	)

Schedule Of Income Tax Expense Benefit

Income tax expense consists of:

	Current				Deferred				Total
	in millions
Year ended December 31, 2019:
The Netherlands	$	—			$	(275.3	)		$	(275.3	)
Belgium	(134.7		)		3.6				(131.1		)
U.K.	(1.5		)		118.8				117.3
U.S. (a)	(4.1		)		81.9				77.8
Switzerland	(27.8		)		(1.1		)		(28.9		)
Other	(19.4		)		6.6				(12.8		)
Total	$	(187.5	)		$	(65.5	)		$	(253.0	)
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	)

_______________

(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 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,
	2019				2018				2017
	in millions
Computed “expected” tax benefit (expense) (a)	$	219.6			$	(30.7	)		$	406.4
Non-deductible or non-taxable interest and other expenses	(191.7		)		(153.8		)		(42.8		)
Basis and other differences in the treatment of items associated with investments in subsidiaries and affiliates (b)	(167.9		)		(360.1		)		(192.6		)
Change in valuation allowances	(113.6		)		(34.9		)		(341.6		)
Non-deductible or non-taxable foreign currency exchange results	(26.5		)		132.5				(233.8		)
Enacted tax law and rate changes (c)	19.2				(13.5		)		7.4
International rate differences (d)	8.5				(3.5		)		126.9
Recognition of previously unrecognized tax benefits	5.9				49.6				4.9
Mandatory Repatriation Tax (e)	—				(1,137.2		)		—
Tax benefit associated with technologies innovation	—				—				12.1
Other, net	(6.5		)		(21.7		)		14.2
Total income tax expense	$	(253.0	)		$	(1,573.3	)		$	(238.9	)

_______________

(a) The statutory or “expected” tax rates are the U.K. rates of 19.0% for 2019, 19.0% for 2018 and 19.25% for 2017. 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) 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.

(c) On December 27, 2019, updated legislation was enacted in the Netherlands to delay and lessen the corporate income tax rate reduction that had previously been enacted in December 2018. The current rate of 25% will now be maintained in 2020 and will be reduced to 21.7% in 2021; the previous reduction schedule reduced from the current rate of 25.0% to 22.5% in 2020 and 20.5% in 2021. Substantially all of the impacts of the new rate change in the Netherlands on our deferred tax balances were recorded during the fourth quarter of 2019, modifying the impacts of the 2018 rate change that were previously 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.

(d) 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.

(e) 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.

Schedule Of Current And Noncurrent Deferred Tax Assets And Liabilities

The components of our net deferred tax assets are as follows: 

	December 31,
	2019				2018
	in millions
Deferred tax assets	$	2,457.4			$	2,488.2
Deferred tax liabilities (a)	(246.4		)		(232.9		)
Net deferred tax asset	$	2,211.0			$	2,255.3

_______________ 

(a) Our deferred tax liabilities are included in other long-term liabilities on 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,
	2019				2018
	in millions
Deferred tax assets:
Net operating loss and other carryforwards	$	4,367.5			$	4,289.8
Property and equipment, net	1,969.0				1,923.4
Debt	231.5				317.3
Investments	136.4				156.2
Derivative instruments	113.3				72.5
Share-based compensation	76.5				79.5
Leases	58.5				5.6
Other future deductible amounts	132.3				176.1
Deferred tax assets	7,085.0				7,020.4
Valuation allowance	(4,235.5		)		(4,094.7		)
Deferred tax assets, net of valuation allowance	2,849.5				2,925.7
Deferred tax liabilities:
Property and equipment, net	(169.9		)		(167.4		)
Deferred revenue	(168.1		)		(178.9		)
Intangible assets	(114.1		)		(193.8		)
Debt	(65.7		)		(91.0		)
Right of use assets	(56.8		)		—
Other future taxable amounts	(63.9		)		(39.3		)
Deferred tax liabilities	(638.5		)		(670.4		)
Net deferred tax asset	$	2,211.0			$	2,255.3

Summary of Operating Loss Carryforwards

The significant components of our tax loss carryforwards and related tax assets at December 31, 2019 are as follows: 

Country		Tax loss carryforward				Related tax asset				Expiration date
		in millions
U.K.:
Amount attributable to capital losses		$	16,052.0			$	2,728.8			Indefinite
Amount attributable to net operating losses		1,222.4				207.8				Indefinite
The Netherlands		3,204.0				696.2				2020-2025
Belgium		1,320.4				330.1				Indefinite
Ireland		713.8				89.4				Indefinite
Luxembourg		586.4				159.4				Indefinite
France		533.3				137.8				Indefinite
Other		416.8				18.0				Various
Total		$	24,049.1			$	4,367.5

Unrecognized Tax Benefits Roll Forward

The changes in our unrecognized tax benefits are summarized below: 

	2019				2018				2017
	in millions
Balance at January 1	$	857.8			$	350.4			$	217.0
Settlements with tax authorities	(111.3		)		—				(3.6		)
Reductions for tax positions of prior years	(80.7		)		(117.9		)		(20.4		)
Foreign currency translation	(4.3		)		(8.5		)		14.1
Additions based on tax positions related to the current year	1.8				180.0				4.5
Additions for tax positions of prior years	1.0				457.4				138.8
Lapse of statute of limitations	—				(3.6		)		—
Balance at December 31	$	664.3			$	857.8			$	350.4

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