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Income Taxes | 12 Months Ended
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Dec. 31, 2019
Income Tax Disclosure [Abstract] |
Income Taxes | (5) Income Taxes The provision for income taxes was as follows:
Year Ended December 31 |  | 2019 |  |  | 2018 |  |  | 2017 |
Current |  |  |  |  |  |  |  |  |  |  |  |
United States |  |  |  |  |  |  |  |  |  |  |  |
Federal |  | $ | 16.7 |  |  | $ | 17.2 |  |  | $ | 211.7 |
State |  |  | 2.5 |  |  |  | 10.8 |  |  |  | 8.4 |
Non-United States |  |  | 243.6 |  |  |  | 181.9 |  |  |  | 168.6 |
Total current |  |  | 262.8 |  |  |  | 209.9 |  |  |  | 388.7 |
Deferred |  |  |  |  |  |  |  |  |  |  |  |
United States |  |  |  |  |  |  |  |  |  |  |  |
Federal |  |  | (22.1 | ) |  |  | (7.5 | ) |  |  | (178.2 | )
State |  |  | 1.1 |  |  |  | 1.0 |  |  |  | (0.8 | )
Non-United States |  |  | (22.0 | ) |  |  | (5.4 | ) |  |  | (17.8 | )
Total deferred |  |  | (43.0 | ) |  |  | (11.9 | ) |  |  | (196.8 | )
Total provision |  | $ | 219.8 |  |  | $ | 198.0 |  |  | $ | 191.9 |
A tax reconciliation between taxes computed at the United States federal statutory rate of 21% for 2019 and 2018 and 35% for 2017 and the consolidated effective tax rate is as follows:
Year Ended December 31 |  | 2019 |  |  | 2018 |  |  | 2017 |
Income tax based on statutory rate |  | $ | 143.9 |  |  | $ | 158.5 |  |  | $ | 258.1 |
Increase (decrease) resulting from: |  |  |  |  |  |  |  |  |  |  |  |
Non-United States tax rate difference: |  |  |  |  |  |  |  |  |  |  |  |
French business tax(1) |  |  | 54.9 |  |  |  | 59.1 |  |  |  | 46.9 |
French CICE(2) |  |  | — |  |  |  | (39.9 | ) |  |  | (77.1 | )
Other(1)(2) |  |  | 37.3 |  |  |  | 20.0 |  |  |  | (28.6 | )
Repatriation of non-United States earnings(2)(3) |  |  | (17.8 | ) |  |  | 2.5 |  |  |  | 69.7 |
State income taxes, net of federal benefit |  |  | 3.1 |  |  |  | 8.2 |  |  |  | 1.1 |
Change in valuation allowance |  |  | 20.0 |  |  |  | 0.7 |  |  |  | (6.9 | )
Work Opportunity Tax Credit |  |  | (10.4 | ) |  |  | (8.8 | ) |  |  | (10.5 | )
Foreign-Derived Intangible Income deduction |  |  | (11.9 | ) |  |  | (12.5 | ) |  |  | — |
United States Tax Act and French tax reform(3) |  |  | — |  |  |  | 3.2 |  |  |  | (73.7 | )
Goodwill impairment(4) |  |  | 11.9 |  |  |  | — |  |  |  | — |
Gain related to Manpower Switzerland and Greater China transactions(5) |  |  | (22.8 | ) |  |  | — |  |  |  | — |
Other, net |  |  | 11.6 |  |  |  | 7.0 |  |  |  | 12.9 |
Tax provision |  | $ | 219.8 |  |  | $ | 198.0 |  |  | $ | 191.9 |
(1) The French business tax is allowed as a deduction for French income tax purposes. The gross amount of the French business tax was $69.5, $74.8 and $72.1 for 2019, 2018 and 2017, respectively. The amounts in the table above of $54.9, $59.1 and $46.9 for 2019, 2018 and 2017, respectively, represent the French business tax expense net of the French tax benefit using the United States federal rate of 21% for 2019 and 2018 and 35% for 2017. Included in Other Non-United States tax rate differences are a benefit of $9.3 and $10.1 for 2019 and 2018, respectively, and an expense of $0.4 for 2017 related to the difference between the United States federal rate and the French tax rate applied to the respective gross amounts of the French business tax. (2) The French CICE was a payroll tax credit that was tax-free for French tax purposes and increased French earnings. The amounts in the table above of $39.9 and $77.1 for 2018 and 2017, respectively, represent the French tax benefits using the United States federal rate of 21% for 2018 and 35% for 2017. Included in Other Non-United States tax rate differences are a benefit of $25.5 for 2018 and an expense of $1.3 for 2017 related to the difference between the United States federal rate and French tax rate applied to the respective gross French CICE amounts. In January 2019, the French government replaced the CICE subsidy with new subsidies that are taxable. (3) Prior to the enactment of the Tax Act on December 22, 2017, we recorded $83.3 of tax expense in 2017 related to non-United States earnings that were deemed to be not permanently invested. This amount was included in the Repatriation of non-United States earnings consistent with prior years. As a result of the Tax Act, this $83.3 was reversed as we were no longer recording United States federal income tax expense on these earnings, and this tax benefit was included in the United States Tax Act and French tax reform benefit of $73.7. (4) Non-deductible portion of the goodwill impairment charge recorded in Germany in June 2019. (5) Non-taxable gains on the disposition of our previously held equity interest in Manpower Switzerland in April 2019 and the deconsolidation of ManpowerGroup Greater China Limited in July 2019. Deferred income taxes are recorded based on temporary differences at the tax rate expected to be in effect when the temporary differences reverse. The Tax Act significantly impacted our deferred income taxes. Temporary differences, which give rise to the deferred taxes, are as follows:
December 31 |  | 2019 |  |  | 2018 |
Future Income Tax Benefits (Expense) |  |  |  |  |  |  |  |
Accrued payroll taxes and insurance |  | $ | 12.8 |  |  | $ | 13.8 |
Employee compensation payable |  |  | 27.2 |  |  |  | 17.8 |
Pension and postretirement benefits |  |  | 62.3 |  |  |  | 46.9 |
Intangible assets |  |  | (108.7 | ) |  |  | (102.1 | )
Repatriation of non-United States earnings |  |  | (8.8 | ) |  |  | (15.3 | )
Loans denominated in foreign currencies |  |  | (16.4 | ) |  |  | (19.6 | )
Operating lease ROU assets |  |  | (115.8 | ) |  |  | — |
Operating lease liabilities |  |  | 118.1 |  |  |  | — |
Net operating losses |  |  | 89.5 |  |  |  | 100.5 |
Other |  |  | 135.0 |  |  |  | 97.4 |
Valuation allowance |  |  | (87.8 | ) |  |  | (72.4 | )
Total future tax benefits |  | $ | 107.4 |  |  | $ | 67.0 |
Deferred tax asset |  | $ | 126.2 |  |  | $ | 99.3 |
Deferred tax liability |  |  | (18.8 | ) |  |  | (32.3 | )
Total future tax benefits |  | $ | 107.4 |  |  | $ | 67.0 |
Pre-tax earnings of non-United States operations were $416.6, $551.0 and $514.9 in 2019, 2018 and 2017, respectively. We have not provided deferred taxes on $371.5 of unremitted earnings of non-United States subsidiaries that are considered permanently invested. As of December 31, 2019, deferred taxes for non-United States withholding and other taxes were provided on $1,867.0 of unremitted earnings of non-United States subsidiaries that may be remitted to the United States. As of December 31, 2019 and 2018, we have recorded a deferred tax liability of $8.8 and $15.3, respectively, related to these non-United States earnings that may be remitted. We had United States federal and non-United States net operating loss carryforwards and United States state net operating loss carryforwards totaling $399.4 and $169.2, respectively, as of December 31, 2019. The net operating loss carryforwards expire as follows:
|  | United States Federal and Non-United States |  |  | United States State |
2020 |  | $ | 2.1 |  |  | $ | 0.2 |
2021 |  |  | 5.3 |  |  |  | 3.0 |
2022 |  |  | 3.8 |  |  |  | 11.1 |
2023 |  |  | 3.9 |  |  |  | 9.8 |
2024 |  |  | 5.7 |  |  |  | 57.3 |
Thereafter |  |  | 25.2 |  |  |  | 87.8 |
No expirations |  |  | 353.4 |  |  |  | — |
Total net operating loss carryforwards |  | $ | 399.4 |  |  | $ | 169.2 |
We have recorded a deferred tax asset of $89.5 as of December 31, 2019, for the benefit of these net operating losses. Realization of this asset is dependent on generating sufficient taxable income prior to the expiration of the loss carryforwards. A related valuation allowance of $72.7 was recorded as of December 31, 2019, as management believed that realization of certain net operating loss carryforwards is unlikely. As of December 31, 2019, we had gross unrecognized tax benefits related to various tax jurisdictions, including interest and penalties, of $69.5 that would favorably affect the effective tax rate if recognized. During 2019, we filed our 2018 United States federal tax return with a position related to the transition tax imposed as part of the Tax Act, resulting in an increase to our unrecognized tax benefits of $32.0 with minimal impact to the tax provision. We do not expect our unrecognized tax benefits to change significantly over the next year. As of December 31, 2018, we had gross unrecognized tax benefits related to various tax jurisdictions, including interest and penalties, of $34.2. We recognize accrued interest and penalties related to unrecognized tax benefits in income tax expense. In 2019, we accrued net interest and penalties of $1.6. In 2018, we recognized a reduction of interest and penalties due to the settlement of tax litigation of $18.4. We accrued net interest and penalties of $0.2 in 2017. The following table summarizes the activity related to our unrecognized tax benefits during 2019, 2018 and 2017:
|  | 2019 |  |  | 2018 |  |  | 2017 |
Gross unrecognized tax benefits, beginning of year |  | $ | 32.2 |  |  | $ | 46.1 |  |  | $ | 23.8 |
Increases in prior year tax positions |  |  | 35.7 |  |  |  | 11.4 |  |  |  | 27.1 |
Decreases in prior year tax positions |  |  | (2.6 | ) |  |  | (1.8 | ) |  |  | (1.2 | )
Increases for current year tax positions |  |  | 4.7 |  |  |  | 5.9 |  |  |  | 6.6 |
Expiration of statute of limitations and audit settlements |  |  | (4.1 | ) |  |  | (29.4 | ) |  |  | (10.2 | )
Gross unrecognized tax benefits, end of year |  | $ | 65.9 |  |  | $ | 32.2 |  |  | $ | 46.1 |
Potential interest and penalties |  |  | 3.6 |  |  |  | 2.0 |  |  |  | 20.4 |
Balance, end of year |  | $ | 69.5 |  |  | $ | 34.2 |  |  | $ | 66.5 |
We conduct business globally in various countries and territories. We are routinely audited by the tax authorities of the various tax jurisdictions in which we operate. Generally, the tax years that could be subject to examination are 2012 through 2019 for our major operations in France, Germany, Japan, the United Kingdom and the United States. As of December 31, 2019, we were subject to tax audits in Austria, Canada, Denmark, Germany, Israel, and the United States. We believe that the resolution of these audits will not have a material impact on earnings.

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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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