Note 7 – Income Taxes

Income from continuing operations before income taxes was generated in the following jurisdictions. For the year ended December 31, 2014, 2013, and 2012, domestic income excludes taxable intercompany dividend income of $30,650, $30,752, and $0, respectively.


	For the year ended December 31,
	2014			2013			2012
Domestic	$	(3,294	)	$	(2,024	)	$	1,492
Foreign		41,214			16,138			20,205

Total	$	37,920		$	14,114		$	21,697

The provision for income taxes consists of the following:


	For the year ended December 31,
	2014			2013			2012
Current:
Federal	$	—		$	11		$	—
State		42			22			1
Foreign		4,688			3,121			4,402

Total current		4,730			3,154			4,403

Deferred:
Federal		(497	)		338			866
State		361			(289	)		93
Foreign		715			(56	)		106

Total deferred		579			(7	)		1,065

Total	$	5,309		$	3,147		$	5,468

The U.S. federal corporate tax rate varies with taxable income. For 2014 and 2013, our statutory rate was 35%. Our statutory rate for 2012 was 34%. The differences between the income tax provisions computed using the statutory federal income tax rate and the provisions for income taxes reported in the consolidated statements of operations are as follows:


	For the years ended December 31,
	2014			2013			2012
Expected tax at statutory rate	$	13,272		$	4,940		$	7,377
Foreign taxes at other rates		(9,107	)		(2,520	)		(2,513	)
US tax on foreign earnings, net of foreign tax credits		(9	)		212			—
State income taxes, net of federal benefit		140			(310	)		53
Disallowed expenses and other		1,013			825			551

Total	$	5,309		$	3,147		$	5,468

Current deferred tax assets and long-term deferred tax liabilities are presented as separate line items in the balance sheet. Long-term deferred tax assets of $6,885 and $6,334 as of December 31, 2014 and 2013, respectively, are included in other assets, net of accumulated amortization. Current deferred tax liabilities as of December 31, 2014 and 2013 of $1,235 and $726, respectively, are included in other accrued liabilities. Deferred income tax balances are comprised of the following:


	As of December 31,
	2014			2013
Deferred tax assets:
U.S. foreign tax credit	$	5,516		$	5,058
Stock and long-term compensation plans		1,693			1,318
Foreign NOL & other carryforwards		2,629			2,930
US state income taxes		263			574
US alternative minimum tax		395			395
Deferred revenue		752			965
Reserve for uncertain tax issues		(560	)		(560	)
Amortization and depreciation		434			195
US tax on unremitted foreign earnings		(955	)		(380	)
Accrued expenses and other		124			(128	)

Total gross deferred tax assets		10,291			10,367
Less: Valuation allowance		(2,500	)		(2,399	)

Net deferred income tax assets	$	7,791		$	7,968

Deferred tax liabilities:
Swiss tax allowances	$	1,235		$	726
Intangible assets		213			321

Deferred tax liabilities	$	1,448		$	1,047

Current deferred tax assets and liabilities are netted by tax jurisdiction. Similarly, long-term, deferred tax assets and liabilities are netted by tax jurisdiction.

Prior to 2013, we considered unremitted foreign earnings permanently invested and, consequently, did not provide deferred incremental U.S. taxes on them. In 2013, we determined earnings of certain subsidiaries are available for distribution. At December 31, 2014 and 2013, unremitted foreign earnings available for distribution are $19,849 and $46,012, respectively. The deferred tax liability for the incremental U.S. tax to be paid upon remittance as dividends at December 31, 2014 and 2013 was $955 and $380, respectively.

The earnings of certain subsidiaries remain permanently invested. At December 31, 2014 and 2013, total unremitted foreign earnings considered permanently invested are $83,122 and $50,398, respectively.

We utilized U.S. net operating loss (NOL) carryforwards of $10,586 in 2013 including $9,741 related to employee stock options. The stock option tax benefit of $3,318 was credited to additional paid-in capital.

Foreign tax credit carryforwards were $5,516 at December 31, 2014. Foreign tax credits of $944 expire in 2015 and the remaining $4,572 expire in 2023 and 2024. We have not provided a valuation reserve for the foreign tax credits as we believe it is more likely than not they will be realized due to our tax strategy to distribute foreign earnings to utilize foreign tax credits prior to expiration.

At December 31, 2014, we had foreign NOL carryforwards of $4,366 and other foreign deductible carryforwards of $3,568. The foreign NOL carryforwards have no expiration dates and the other deductible carryforwards expire from 2016 to 2021. At December 31, 2014, we had a valuation allowance of $2,378 for certain foreign deferred tax assets and $122 for a U.S. state NOL carryforward.

The net change in the valuation allowance for the years ended December 31, 2014, 2013, and 2012, were increases of $101, $115 and $196, respectively. This valuation allowance will be reviewed on a regular basis and adjustments made as appropriate. In addition to the utilization of NOLs as noted above, the change in the valuation allowance also reflects other factors including, but not limited to, changes in our assessment of our ability to use existing NOLs and other deduction carryforwards, changes in currency rates, and adjustments to reflect differences between the actual returns filed and the estimates we made at financial reporting dates. The company expects to generate adequate taxable income to realize deferred tax assets in foreign jurisdictions where no valuation reserve exists.

We had no accrued interest or penalties for income tax liabilities at December 31, 2014. Our policy is to record interest expense and penalties on income taxes as income tax expense.

ASC 740-10, Accounting for Uncertainty in Income Taxes sets a “more likely than not” criterion for recognizing the tax benefit of uncertain tax positions. We have identified one such exposure concerning cost allocations related to the implementation of our worldwide strategy related to the ownership of our intellectual property for which we had a reserve of $560 at December 31, 2014 and 2013. The reserve is an offset to our U.S. deferred tax asset.

Our primary tax jurisdictions and the earliest tax year subject to audit are presented in the following table.


Australia			2005
Austria			2008
Belgium			2008
Netherlands			2009
Singapore			2007
Switzerland			2011
United States			2005