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Income Taxes | 6 Months Ended
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Jun. 30, 2018
Income Tax Disclosure [Abstract] |
INCOME TAXES | INCOME TAXES For the second quarter of 2018, we recorded tax expense of $19 million on income before income taxes of $183 million. For the first six months of 2018, we recorded tax expense of $52 million on income before income taxes of $296 million. Income tax expense for the three and six months ended June 30, 2018 includes discrete benefits of $28 million and $21 million, respectively. The net discrete tax benefit includes a second quarter benefit of $25 million from recording foreign tax credits on dividends, primarily from subsidiaries in Japan and Singapore, to the United States, and a first quarter charge of $7 million and a second quarter benefit of $4 million to adjust our provisional tax obligation for the one-time transition tax imposed by the Tax Cuts and Jobs Act (the "Tax Act") that was enacted on December 22, 2017 in the United States. The one-time transition tax is a tax on certain previously untaxed accumulated earnings and profits of our foreign subsidiaries. We were able to reasonably estimate the one-time transition tax and record an initial provisional tax obligation of $77 million at December 31, 2017. During the first quarter of 2018, the one-time transition tax obligation increased by $7 million as a result of guidance that required the tax to be calculated using year-end exchange rates as opposed to average exchange rates. During the second quarter of 2018, the obligation decreased by $4 million as a result of guidance that clarified that certain accrued income taxes can reduce the amount subject to the one-time transition tax. Accordingly, as of June 30, 2018, we have now recorded a provisional transition tax obligation totaling $80 million. At December 31, 2017, we established a provisional reserve of $19 million related to foreign withholding taxes that we would incur should we repatriate certain earnings. During the three months ending June 30, 2018, our reserve decreased to $8 million to reflect payments of withholding tax on dividends from foreign subsidiaries. We continue to consider new guidance related to these provisional amounts and are in the process of gathering and analyzing additional information with respect to our 2017 earnings and profits to more precisely compute the amount of the one-time transition tax. In the second quarter of 2017, we recorded tax expense of $36 million on income before income taxes of $190 million. For the first six months of 2017, we recorded tax expense of $106 million on income before income taxes of $429 million. Income tax expense for the three and six months ended June 30, 2017 was favorably impacted by $9 million and $11 million, respectively, of various discrete tax adjustments. We record taxes based on overall estimated annual effective tax rates. The difference between our effective tax rate for the three and six months ended June 30, 2018 and the U.S. statutory rate of 21% primarily relates to the discrete items noted above and a benefit from our foreign derived intangible income deduction provided for in the Tax Act, partially offset by an overall higher effective tax rate in the foreign jurisdictions in which we operate. The difference between our effective tax rate for the three and six months ended June 30, 2017 and the then applicable U.S. statutory rate of 35% was primarily attributable to the discrete items noted above and an overall lower effective tax rate in the foreign jurisdictions in which we operate. The Tax Act subjects a U.S. parent to the base erosion minimum tax ("BEAT") and a current tax on its global intangible low-taxed income ("GILTI"). We have elected to recognize the resulting tax on GILTI as a period expense in the period the tax is incurred. We estimate that the impact from the BEAT and GILTI taxes will not be material to our income tax provision. Our losses in various foreign taxing jurisdictions in recent periods represented sufficient negative evidence to require us to maintain a full valuation allowance against certain of our net deferred tax assets. Each reporting period we assess available positive and negative evidence and estimate if sufficient future taxable income will be generated to utilize these existing deferred tax assets. If recent positive evidence provided by the profitability in our Brazilian subsidiary continues, it will provide us the opportunity to apply greater significance to our forecasts in assessing the need for a valuation allowance. We believe it is reasonably possible that sufficient positive evidence required to release all, or a portion, of its valuation allowance will exist within the next twelve months. This may result in a reduction of the valuation allowance and a one-time tax benefit of up to $20 million. Based on positive evidence and future sources of income in the U.S., it is more likely than not that our foreign tax credits of approximately $750 million as of December 31, 2017, will be fully utilized. We are open to examination in the United States for 2017 and in Germany from 2013 onward. Generally, for our remaining tax jurisdictions, years from 2012 onward are still open to examination.

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- Definition The entire disclosure for income taxes. Disclosures may include net deferred tax liability or asset recognized in an enterprise's statement of financial position, net change during the year in the total valuation allowance, approximate tax effect of each type of temporary difference and carryforward that gives rise to a significant portion of deferred tax liabilities and deferred tax assets, utilization of a tax carryback, and tax uncertainties information. + References Reference 1: http://fasb.org/us-gaap/role/ref/legacyRef -Publisher FASB -Name Accounting Standards Codification -Topic 740 -URI http://asc.fasb.org/topic&trid=2144680 + Details
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