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Income Taxes
 9 Months Ended
Sep. 30, 2012
Income Taxes [Abstract]  
INCOME TAXES

NOTE 7 – INCOME TAXES

A roll-forward of unrecognized tax benefits and associated accrued interest and penalties is as follows:

 

                         

(in millions)

   Interest and
Penalties		     Unrecognized
Tax Benefits		     Total  

Opening balance at January 1, 2012

   $ 0.4     $ 12.2     $ 12.6  

Additions for tax positions of prior periods

     0.1       0.0       0.1  

Reductions for tax positions of prior periods

     0.0       (0.2 )      (0.2 ) 
   

 

 

    

 

 

    

 

 

  

Closing balance at September 30, 2012

     0.5       12.0       12.5  

Current

     (0.3 )      (2.7 )      (3.0 ) 
   

 

 

    

 

 

    

 

 

  

Non-current

   $ 0.2     $ 9.3     $ 9.5  
   

 

 

    

 

 

    

 

 

  

All of the $12.5 million of unrecognized tax benefits, and interest and penalties, would impact our effective tax rate if recognized.

We recognize accrued interest and penalties associated with uncertain tax positions as part of income taxes in our consolidated statements of income.

The Company or one of its subsidiaries files income tax returns in the U.S. federal jurisdiction, and various state and foreign jurisdictions. As at September 30, 2012, the Company’s subsidiaries in the U.S. were subject to state tax audits in various states and the Company’s German subsidiaries were subject to tax audits in Germany. The Company does not currently anticipate that adjustments, if any, arising out of these tax audits would result in a material change to its financial position as at September 30, 2012.

The Company and its U.S. subsidiaries remain open to federal income tax examination by the IRS for years 1998 to 2004 and 2007 onwards due to the net operating losses in the period 1998 to 2002, although no examination is currently underway. The Company’s subsidiaries in foreign tax jurisdictions are open to examination including France (2009 onwards), Germany (2006 onwards), Switzerland (2010 onwards) and the United Kingdom (2010 onwards).

 

The Company is in a position to control whether or not to repatriate foreign earnings. No taxes have been provided for the unremitted earnings of our overseas subsidiaries as any tax basis differences relating to investments in these overseas subsidiaries are considered to be permanent in duration.