XML 56 R14.htm IDEA: XBRL DOCUMENT v3.19.3
Income Taxes - (Notes)
9 Months Ended
Sep. 30, 2019
Income Tax Disclosure [Abstract]  
INCOME TAXES INCOME TAXES
Our effective income tax rate was 18% and 16% for the third quarter of 2019 and 2018, respectively, and 20% and 18% for the nine months ended September 30, 2019 and 2018, respectively. The increase in rate for the third quarter of 2019 was primarily due to a decrease in tax credits and a benefit from revaluation of deferred taxes recorded in the prior year. The increase in rate for the year to date for 2019 when compared to the same period in 2018 consists primarily of decreases in excludable income for state tax purposes and tax benefits recognized from excess tax benefits related to stock based compensation in addition to an increase in uncertain tax positions. These expenses are partially offset by a one-time benefit associated with prior year tax expense.
During the nine months ended September 30, 2019, there was an increase of $1 million in our unrecognized tax benefits. The total amount of gross interest and penalties accrued was immaterial. It is reasonably possible the amount of the unrecognized benefit could increase or decrease within the next twelve months, which would have an impact on net income.
We are subject to tax in U.S. federal and various state and local jurisdictions, as well as Canada. We are open to federal and significant state income tax examinations for tax years 2015 and subsequent years.
We previously paid Notices of Proposed Assessments disallowing employment tax credits totaling $11 million, plus interest of $4 million in connection with the IRS examination of Gevity HR, Inc. and its subsidiaries, which was acquired by TriNet in June 2009. TriNet filed suit in June 2016 to recover the disallowed credits, and the issue is being resolved through the litigation process. TriNet and the U.S. filed cross motions for summary judgment in this matter in federal district court on February 27, 2018. On September 17, 2018, the district court granted our motion for summary judgment and denied the U.S.' motion. On January 18, 2019, the district court entered judgment in favor of TriNet in the amount of $15 million, plus interest. The U.S. filed a notice of appeal of the district court's decision on March 18, 2019. The U.S. filed its opening brief in the court of appeals on June 10, 2019 and we filed our answering brief on July 24, 2019 to which the government filed its reply brief on September 6, 2019. We will continue to vigorously defend our position through the litigation process.