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Income Taxes | 6 Months Ended
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Jun. 30, 2019
Income Tax Disclosure [Abstract] |
Income Taxes | Income Taxes The Company’s effective income tax rate for the three and six month periods ended June 30, 2019 was 16.8% and nil compared to (226.5)% and 20.3% for the three-month and six-month periods ended June 30, 2018, respectively. The Company’s effective income tax rate fluctuates based on, among other factors, the geographic mix of income. The difference between the U.S. federal statutory income tax rate of 21.0% and the Company’s effective income tax rate for the three-month and six-month periods ended June 30, 2019 was impacted by a variety of factors, primarily resulting from the geographic mix of where the income was earned as well as certain taxable income inclusion items in the U.S. based on foreign earnings. Income tax expense for the three-month and six-month period ended June 30, 2019 included a discrete tax benefit of $(13.2) million for a withholding tax refund received from Switzerland by the Company and $(10.7) million related to change in tax status of certain entities in various non-U.S. jurisdictions, offset by discrete tax expense of $14.4 million for excess book deductions for equity-based compensation and $4.6 million for the accrual of interest related to the Company’s uncertain tax liabilities. In addition, income tax expense for the six-month period ended June 30, 2019 included discrete tax adjustments of $(10.1) million for certain state tax return to provision adjustments offset by tax expense of $3.8 million for additional interest related to uncertain tax liabilities. The difference between the U.S. federal statutory income tax rate of 21% and the Company’s effective income tax rate for the three-month and six-month periods ended June 30, 2018 was primarily resulting from the geographic mix of where the income was earned, certain taxable income inclusion items in the U.S. based on foreign earnings, and the generation of excess foreign tax credits. In addition, income tax expense for the three-month and six-month period ended June 30, 2018 included a discrete tax benefit of $(0.7) million for return to provision adjustments, offset by tax expense of $3.8 million for interest related to the Company’s uncertain tax liabilities and $11.0 million for excess book deductions related to equity-based compensation. In addition, income tax expense for the six-month period ended June 30, 2018 included discrete tax adjustments of $(69.4) million for a reduction in valuation allowance related to the Company's operations in France, $(5.2) million for excess tax deductions related to equity-based compensation, and $(6.8) million related to the change in tax status of certain non-U.S. operations, offset by $26.1 million of tax expense for related to certain tax audits in Europe and $2.2 million of interest related to uncertain tax liabilities. On June 18, 2019, the U.S. Treasury and the Internal Revenue Service released temporary regulations under IRC Section 245A (“Section 245A”) as enacted by the 2017 U.S. Tax Reform Legislation (“2017 Tax Reform”) and IRC Section 954(c)(6) (the “Temporary Regulations”) to apply retroactively to the date the 2017 Tax Reform was enacted. The Temporary Regulations seek to limit the 100% dividends received deduction permitted by Section 245A for certain dividends received from controlled foreign corporations and to limit the applicability of the look-through exception to foreign personal holding company income for certain dividends received from controlled foreign corporations. Before the retroactive application of the Temporary Regulations, the Company benefited in 2018 from both the 100% dividends received deduction and the look-through exception to foreign personal holding company income. The Company has analyzed the Temporary Regulations and concluded that the relevant Temporary Regulations were not validly issued. Therefore, the Company has not accounted for the effects of the Temporary Regulations in its Condensed Consolidated Financial Statements for the period ending June 30, 2019. The Company believes it has strong arguments in favor of its position and believes it has met the more likely than not recognition threshold that its position will be sustained. However, due to the inherent uncertainty involved in challenging the validity of regulations as well as a potential litigation process, there can be no assurances that the relevant Temporary Regulations will be invalidated or that a court of law will rule in favor of the Company. If the Company’s position on the Temporary Regulations is not sustained, the Company would be required to recognize an income tax expense of approximately $180 million to $220 million related to an income tax benefit from fiscal year 2018 that was recorded based on regulations in existence at the time. In addition, the Company may be required to pay any applicable interest and penalties. The Company intends to vigorously defend its position.

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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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