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Income Taxes
6 Months Ended
Jun. 30, 2014
Income Tax Disclosure [Abstract]  
Income Taxes
Income Taxes
For the six months ended June 30, 2014, the company recorded income tax expense of $21.8 million, compared to income tax expense of $17.8 million for the six months ended June 30, 2013. The increase in the company's tax expense for the six months ended June 30, 2014 relative to the prior year resulted primarily from favorable audit resolutions in the prior year.  The company's effective tax rate varies from the U.S. federal statutory rate of 35% due to results of foreign operations that are subject to income taxes at different statutory rates and certain jurisdictions where the company cannot recognize tax benefits on current losses.
As of each reporting date, the company's management considers new evidence, both positive and negative, that could impact management's view with regard to future realization of deferred tax assets. As of June 30, 2014, in part because in the current quarter the company's crane operations achieved three years of cumulative pre-tax income in the China tax jurisdiction, management determined that sufficient positive evidence exists to conclude that it is more likely than not that additional deferred taxes of $9.0 million are realizable, and therefore, reduced the valuation allowance accordingly.
The company will continue to periodically evaluate its valuation allowance requirements in light of changing facts and circumstances, and may adjust its deferred tax asset valuation allowances accordingly. It is reasonably possible that the company will either add to, or reverse a portion of its existing deferred tax asset valuation allowances in the future. Such changes in the deferred tax asset valuation allowances will be reflected in the current operations through the company’s income tax provision, and could have a material effect on operating results.
The company’s unrecognized tax benefits, excluding interest and penalties, were $34.2 million as of June 30, 2014, and $35.9 million as of December 31, 2013.  All of the company’s unrecognized tax benefits as of June 30, 2014, if recognized, would impact the effective tax rate. During the next twelve months, it is reasonably possible that federal, state and foreign tax audit resolutions could reduce unrecognized tax benefits by up to $10.9 million, either because the company’s tax positions are sustained on audit or settled, or the applicable statute of limitations closes.
Among other regular and ongoing examinations by federal and state jurisdictions globally, the company is under examination by the Internal Revenue Service (“IRS”) for the calendar years 2008 through 2011. In August 2012, the company received a Notice of Proposed Assessment related to the disallowance of the deductibility of a $380.9 million foreign currency loss incurred in calendar year 2008 and proposed adjustments to the research and development credit generated in 2009. The company subsequently filed a formal protest to the proposed adjustments. Following an Appeals conference in September 2013, the Appeals division advised the company that these issues had been tentatively resolved in the company's favor; however, this tentative resolution was subject to review by the Joint Committee on Taxation. In July 2014, the company was notified that its case had been reviewed by the Joint Committee on Taxation and they agreed with the favorable resolution reached by the Appeals division.
The company regularly assesses the likelihood of an adverse outcome resulting from examinations to determine the adequacy of its tax reserves.  As of June 30, 2014, the company believes that it is more-likely-than-not that the tax positions it has taken will be sustained upon the resolution of its audits resulting in no material impact on its consolidated financial position and the results of operations and cash flows.  However, the final determination with respect to any tax audits, and any related litigation, could be materially different from the company’s estimates and/or from its historical income tax provisions and accruals and could have a material effect on operating results and/or cash flows in the periods for which that determination is made.  In addition, future period earnings may be adversely impacted by litigation costs, settlements, penalties, and/or interest assessments.
As of June 30, 2014, there have been no significant developments in the quarter with respect to the company’s other ongoing tax audits in various jurisdictions.