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Income Taxes
 12 Months Ended
Dec. 31, 2021
Income Tax Disclosure [Abstract]  
Income Taxes

(5) Income Taxes

The provision for income taxes was as follows:

 

Year Ended December 31

 

2021

 

 

2020

 

 

2019

 

Current

 

 

 

 

 

 

 

 

 

United States

 

 

 

 

 

 

 

 

 

Federal

 

$

20.2

 

 

$

5.2

 

 

$

16.7

 

State

 

 

3.3

 

 

 

4.5

 

 

 

2.5

 

Non-United States

 

 

163.5

 

 

 

124.6

 

 

 

243.6

 

Total current

 

 

187.0

 

 

 

134.3

 

 

 

262.8

 

Deferred

 

 

 

 

 

 

 

 

 

United States

 

 

 

 

 

 

 

 

 

Federal

 

 

5.8

 

 

 

(11.0

)

 

 

(22.1

)

State

 

 

2.4

 

 

 

(4.9

)

 

 

1.1

 

Non-United States

 

 

(9.5

)

 

 

5.5

 

 

 

(22.0

)

Total deferred

 

 

(1.3

)

 

 

(10.4

)

 

 

(43.0

)

Total provision

 

$

185.7

 

 

$

123.9

 

 

$

219.8

 

 

A tax reconciliation between taxes computed at the United States federal statutory rate of 21% and the consolidated effective tax rate is as follows:

 

Year Ended December 31

 

2021

 

 

2020

 

 

2019

 

Income tax based on statutory rate

 

$

119.3

 

 

$

31.0

 

 

$

143.9

 

Increase (decrease) resulting from:

 

 

 

 

 

 

 

 

 

Non-United States tax rate difference:

 

 

 

 

 

 

 

 

 

French business tax(1)

 

 

26.7

 

 

 

43.7

 

 

 

54.9

 

Other(2)

 

 

22.2

 

 

 

9.7

 

 

 

37.3

 

Repatriation of non-United States earnings

 

 

5.7

 

 

 

(2.0

)

 

 

(17.8

)

State income taxes, net of federal benefit

 

 

5.0

 

 

 

(1.3

)

 

 

3.1

 

Change in valuation allowance(3)

 

 

22.0

 

 

 

48.5

 

 

 

20.0

 

Work Opportunity Tax Credit(4)

 

 

(10.9

)

 

 

(4.9

)

 

 

(10.4

)

Foreign-Derived Intangible Income deduction

 

 

(10.7

)

 

 

(8.8

)

 

 

(11.9

)

Goodwill impairment(5)

 

 

—

 

 

 

13.4

 

 

 

11.9

 

Gain related to Manpower Switzerland and Greater China transactions(6)

 

 

—

 

 

 

—

 

 

 

(22.8

)

Other, net

 

 

6.4

 

 

 

(5.4

)

 

 

11.6

 

Tax provision

 

$

185.7

 

 

$

123.9

 

 

$

219.8

 

 

(1)
The French business tax is allowed as a deduction for French income tax purposes. The gross amount of the French business tax was $33.7, $55.3 and $69.5 for 2021, 2020 and 2019, respectively. The amounts in the table above of $26.7, $43.7 and $54.9 for 2021, 2020 and 2019, respectively, represent the French business tax expense net of the French tax benefit using the United States federal rate of 21%. In December 2020, the French Parliament approved the Finance Bill for 2021 which lowered the business tax rate from 1.5% to 0.75%. The benefit of this tax rate reduction is reflected in our 2021 Consolidated Financial Statements.
(2)
Included in Other Non-United States tax rate differences is the impact of all Non-United States pre-tax earnings and permanent tax differences at the local statutory tax rate versus the United States federal rate of 21%. This includes benefits of $2.5, $6.1 and $9.3 for 2021, 2020 and 2019, respectively, 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 deduction previously mentioned.
(3)
In 2020, we determined that it was more likely than not that certain deferred tax assets in Germany and the Netherlands would not be realized and recorded income tax expense of $36.9 and $8.1, respectively, to establish valuation allowances. Additional losses incurred in 2021 in Germany resulted in an increase in valuation allowance of $20.1.
(4)
The Work Opportunity Tax Credit is currently authorized until December 31, 2025.
(5)
Non-deductible portion of the goodwill impairment charges recorded in Germany in June 2020 and 2019.
(6)
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. Temporary differences, which give rise to the deferred taxes, are as follows:

 

December 31

 

2021

 

 

2020

 

Future Income Tax Benefits (Expense)

 

 

 

 

 

 

Accrued payroll taxes and insurance

 

$

22.5

 

 

$

32.2

 

Employee compensation payable

 

 

38.9

 

 

 

26.2

 

Pension and postretirement benefits

 

 

77.9

 

 

 

79.1

 

Intangible assets

 

 

(135.7

)

 

 

(113.6

)

Repatriation of non-United States earnings

 

 

(16.1

)

 

 

(10.0

)

Loans denominated in foreign currencies

 

 

—

 

 

 

13.5

 

Operating lease ROU assets

 

 

(96.3

)

 

 

(106.2

)

Operating lease liabilities

 

 

99.5

 

 

 

112.0

 

Net operating losses

 

 

129.4

 

 

 

136.2

 

Other

 

 

163.9

 

 

 

127.9

 

Valuation allowance

 

 

(167.1

)

 

 

(149.4

)

Total future tax benefits

 

$

116.9

 

 

$

147.9

 

Deferred tax asset

 

$

135.0

 

 

$

165.7

 

Deferred tax liability

 

 

(18.1

)

 

 

(17.8

)

Total future tax benefits

 

$

116.9

 

 

$

147.9

 

 

Pre-tax earnings of non-United States operations were $433.6, $86.3 and $416.6 in 2021, 2020 and 2019, respectively. We have not provided deferred taxes on $343.8 of unremitted earnings of non-United States subsidiaries that are considered permanently invested. We have not estimated the deferred tax liability on these earnings as such estimation is not practicable to determine or immaterial to the financial statements. As of December 31, 2021, deferred taxes for non-United States withholding and other taxes were provided on $1,473.3 of unremitted earnings of non-United States subsidiaries that may be remitted to the United States. As of December 31, 2021 and 2020, we have recorded a deferred tax liability of $16.1 and $10.0, 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 $644.7 and $161.9, respectively, as of December 31, 2021. The net operating loss carryforwards expire as follows:

 

 

 

United States
Federal and
Non-United
States

 

 

United States
State

 

2022

 

$

2.7

 

 

$

5.4

 

2023

 

 

2.7

 

 

 

8.5

 

2024

 

 

5.3

 

 

 

38.6

 

2025

 

 

5.5

 

 

 

5.3

 

2026

 

 

1.0

 

 

 

9.9

 

Thereafter

 

 

7.5

 

 

 

70.6

 

No expirations

 

 

620.0

 

 

 

23.6

 

Total net operating loss carryforwards

 

$

644.7

 

 

$

161.9

 

 

We have recorded a deferred tax asset of $129.4 as of December 31, 2021, 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 $115.1 was recorded as of December 31, 2021, as management believes that realization of certain net operating loss carryforwards is unlikely.

 

We had gross unrecognized tax benefits related to various tax jurisdictions, including interest and penalties, of $71.8, $64.5 and $69.5 in 2021, 2020 and 2019, respectively. If recognized, the entire amount would favorably affect the effective tax rate except for $6.0. We do not expect our unrecognized tax benefits to change significantly over the next year.

We recognize accrued interest and penalties related to unrecognized tax benefits in income tax expense. We accrued net interest and penalties of $0.9, $0.0 and $1.6 in 2021, 2020 and 2019, respectively.

The following table summarizes the activity related to our unrecognized tax benefits during 2021, 2020 and 2019:

 

 

 

2021

 

 

2020

 

 

2019

 

Gross unrecognized tax benefits, beginning of year

 

$

60.9

 

 

$

65.9

 

 

$

32.2

 

Increases in prior year tax positions

 

 

4.6

 

 

 

1.4

 

 

 

35.7

 

Decreases in prior year tax positions

 

 

(0.4

)

 

 

(4.1

)

 

 

(2.6

)

Increases for current year tax positions

 

 

9.0

 

 

 

3.2

 

 

 

4.7

 

Expiration of statute of limitations and audit settlements

 

 

(6.8

)

 

 

(5.5

)

 

 

(4.1

)

Gross unrecognized tax benefits, end of year

 

$

67.3

 

 

$

60.9

 

 

$

65.9

 

Potential interest and penalties

 

 

4.5

 

 

 

3.6

 

 

 

3.6

 

Balance, end of year

 

$

71.8

 

 

$

64.5

 

 

$

69.5

 

 

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 2014 through 2021 for our major operations in France, Italy, the United Kingdom and the United States. As of December 31, 2021, we were subject to tax audits in Austria, France, Germany, Israel, Japan, Portugal, Spain and the United States. We believe that the resolution of these audits will not have a material impact on earnings.