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Income Taxes
12 Months Ended
Dec. 31, 2021
Income Tax Disclosure [Abstract]  
Income Taxes Income Taxes
For financial reporting purposes, income before income taxes includes the following components ($ in millions):
For the Years Ended December 31,
202120202019
U.S.$28.5 $29.1 $60.0 
Foreign44.6 68.2 36.9 
Total$73.1 $97.3 $96.9 

An analysis of the provision (benefit) for income taxes from continuing operations follows ($ in millions):
For the Years Ended December 31,
202120202019
Current income taxes:
U.S. federal$5.0 $7.3 $8.1 
U.S. state0.7 1.5 0.8 
Foreign11.9 14.8 9.7 
17.6 23.6 18.6 
Deferred income taxes:
U.S. federal7.5 (5.3)2.3 
U.S. state(0.2)1.0 (1.9)
Foreign(34.3)(0.9)(3.8)
(27.0)(5.2)(3.4)
Total$(9.4)$18.4 $15.2 
A reconciliation of income taxes computed at the U.S. Federal statutory income tax rate to the provision for income taxes is as follows ($ in millions): 
For the Years Ended December 31,
202120202019
AmountPercentAmountPercentAmountPercent
Tax provision at U.S. statutory rate$15.4 21.0 %$20.4 21.0 %$20.3 21.0 %
Foreign income tax rate differential2.9 4.0 2.7 2.7 0.6 0.5 
Income from passthrough entities4.2 5.7 2.3 2.3 1.7 1.6 
Branch earnings(0.9)(1.2)— — — — 
Global intangible low tax inclusion4.7 6.4 4.8 4.8 (0.1)(0.1)
Subpart F income1.0 1.3 0.6 0.6 1.0 1.0 
State income tax, net of federal benefit0.5 0.7 1.8 1.8 (0.2)(0.2)
Adjustments to valuation allowances57.0 78.0 (3.9)(3.9)(3.7)(3.8)
Capital loss carryforward(86.5)(118.3)— — — — 
Transition tax— — — — (0.7)(0.6)
Other tax credits(1.4)(2.0)(0.8)(0.8)(2.0)(2.1)
Foreign tax credits(11.0)(15.0)(9.9)(10.0)(3.5)(3.6)
Other foreign operational taxes3.0 4.1 3.5 3.5 2.9 3.0 
Base erosion minimum tax amount2.4 3.3 — — — — 
Non-deductible compensation1.9 2.6 0.4 0.4 1.1 1.1 
Other, net(2.6)(3.5)(3.5)(3.5)(2.2)(2.1)
Provision for income taxes$(9.4)(12.9)%$18.4 18.9 %$15.2 15.7 %

A benefit for income taxes of $9.4 million, a provision for income taxes of $18.4 million and $15.2 million in the years ended December 31, 2021, 2020, and 2019, respectively, resulted in an effective tax rate of (12.9)%, 18.9%, and 15.7% in 2021, 2020, and 2019, respectively. The Company’s effective tax rates differ from the statutory federal income tax rate of 21% due primarily to varying tax rates in foreign jurisdictions, the relative amounts of income we earn in those jurisdictions and adjustments to valuation allowances.

Prior to the passage of the Tax Act, the Company asserted that substantially all of the undistributed earnings of its foreign subsidiaries were considered indefinitely reinvested and accordingly, no deferred taxes were provided. Due to the Tax Act, the Company has significant previously taxed earnings and profits from its foreign subsidiaries, as a result of transition tax, that are generally able to be repatriated free of U. S. federal tax. In addition, future earnings of foreign subsidiaries are generally expected to be able to be repatriated free of U.S. federal income tax because these earnings were taxed in the U.S. under the GILTI regime or would be eligible for a 100% dividends received deduction. The Company does not assert indefinite reinvestment with respect to earnings generated by foreign subsidiaries to the extent of each controlled foreign corporation's earnings and profits and to the extent of any foreign partnership’s U.S. tax capital accounts. The Company has provided for non-U.S. withholding taxes, U.S. federal tax related to currency movement on previously taxed earnings and profits, and U.S. state taxes on unremitted earnings.

Net deferred income tax assets (liabilities) were comprised of the following ($ in millions):
December 31,
20212020
Deferred Tax Assets
Receivable allowances$0.9 $0.5 
Postretirement and other employee benefits17.1 21.0 
Derivatives— 2.5 
Net operating loss and tax credit carryforwards129.6 104.4 
Capital loss carryforward103.1 12.1 
Accruals and other liabilities0.4 0.7 
Intangibles— 37.6 
Other12.6 4.4 
263.7 183.2 
Less: Valuation allowance(232.3)(166.6)
Net deferred income tax assets$31.4 $16.6 
Deferred Tax Liabilities
Net property, plant and equipment$(60.3)$(55.7)
Intangibles(31.3)— 
Investment in subsidiaries(0.6)(3.2)
Derivatives(0.3)— 
Other(0.1)(0.3)
Net deferred income tax liabilities$(92.6)$(59.2)
Total net deferred income tax liabilities$(61.2)$(42.6)

As of December 31, 2021, the Company had approximately $111.8 million of tax-effected operating loss carryforwards available to further reduce future taxable income in various jurisdictions which will expire on various dates as follows:
2021
2022-2041$26.7 
Indefinite85.1 
$111.8 

In addition, the Company has $103.1 million of tax effected capital loss carryforwards, $96.7 million expire between 2024-2026 and $6.4 million are indefinite lived. The Company also has $8.0 million and $2.2 million of foreign tax credits and state tax credits and that will expire between 2029 – 2030, and 2022 – 2036, respectively.

The Company's deferred tax asset valuation allowances are primarily the result of uncertainties regarding the future realization of recorded tax benefits on tax loss, capital loss, and credit carryforwards. The valuation allowance on deferred tax assets as of December 31, 2021, is substantially in the United States and Luxembourg, of $106.9 million and $103.4 million net of a partial valuation allowance release of $35.0 million, respectively. In addition, there is a valuation allowance on ICMS value added tax credits of $4.9 million in Brazil and certain state tax credits of $1.7 million.

The Company's assumptions, judgments and estimates relative to the valuation of these net deferred tax assets take into account available positive and negative evidence of realizability, including recent financial performance, the ability to realize benefits of restructuring and other recent actions, projections of the amount and category of future
taxable income and tax planning strategies. Actual future operating results and the underlying amount and category of income in future periods could differ from the Company's current assumptions, judgments and estimates. The Company believes that it will generate sufficient future taxable income to realize the tax benefits related to the remaining net deferred tax assets.

The following table summarizes the activity related to the Company's unrecognized tax benefits related to income taxes ($ in millions):
December 31,
202120202019
Uncertain tax position balance at beginning of year$2.0 $1.7 $1.1 
Increases related to current year tax positions0.3 0.3 0.6 
Decreases related to expiration of statute of limitations(0.7)— — 
Current year acquisition$8.2 $— $— 
Uncertain tax position balance at end of year$9.8 $2.0 $1.7 

The liability for unrecognized tax benefits included $5.0 million as of December 31, 2021, that if recognized would impact the Company's effective tax rate. We do not anticipate a material decrease in unrecognized tax benefits by the end of 2022 as a result of a lapse of the statute of limitations and other regulatory filings. The Company's policy with respect to penalties and interest in connection with income tax assessments or related to unrecognized tax benefits is to classify penalties as provision for income taxes and interest as interest expense in its Consolidated Statements of Income. There were no material income tax penalties or interest accrued on current year uncertain tax positions during the years ended December 31, 2021, 2020 and 2019. As it relates to the current year 2021 Scapa acquisition, a liability for $1.8 million of interest and penalties was recorded through purchase accounting to goodwill.
 
The Company files income tax returns, including returns for its subsidiaries, with federal, state, local and foreign jurisdictions. The Company finalized Belgium, Scapa France, and China audits, for the tax years, 2017 – 2018, 2017 – 2019, and 2017-2019, respectively during 2021. All expected impacts have been recorded in 2021 or earlier. We are no longer subject to U.S. federal examinations by the IRS for tax years before 2017. The 2015-2021 tax years remain subject to examination by other major tax jurisdictions.