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Income taxes | 12 Months Ended
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Dec. 31, 2023
Income Tax Disclosure [Abstract] |
Income taxes | Income taxes Following is the total loss before income taxes and the provision (benefit) for income taxes.
Year ended December 31, |  | 2023 |  | 2022 |  | 2021
Income (loss) before income taxes |  |  |  |  |  |
United States |  | $ | (545.5) |  |  | $ | (177.2) |  |  | $ | (443.5) |
Foreign |  | 197.7 |  |  | 114.6 |  |  | (18.2) |
Total loss before income taxes |  | $ | (347.8) |  |  | $ | (62.6) |  |  | $ | (461.7) |
Provision (benefit) for income taxes |  |  |  |  |  |
Current |  |  |  |  |  |
United States |  | $ | 8.8 |  |  | $ | 15.9 |  |  | $ | 9.1 |
Foreign |  | 46.0 |  |  | 34.7 |  |  | 38.1 |
Total |  | 54.8 |  |  | 50.6 |  |  | 47.2 |
Deferred |  |  |  |  |  |
Foreign |  | 24.5 |  |  | (8.3) |  |  | (59.1) |
Total provision (benefit) for income taxes |  | $ | 79.3 |  |  | $ | 42.3 |  |  | $ | (11.9) |
Following is a reconciliation of the benefit for income taxes at the United States statutory tax rate to the provision (benefit) for income taxes as reported:
Year ended December 31, |  | 2023 |  | 2022 |  | 2021
United States statutory income tax benefit |  | $ | (73.0) |  |  | $ | (13.2) |  |  | $ | (96.9) |
Income and losses for which no provision or benefit has been recognized |  | 123.2 |  |  | 40.9 |  |  | 91.1 |
Foreign rate differential and other foreign tax expense |  | 12.7 |  |  | 6.4 |  |  | 0.4 |
Income tax withholdings |  | 14.0 |  |  | 19.7 |  |  | 13.5 |
Permanent items |  | (3.0) |  |  | (2.1) |  |  | (1.8) |
Change in uncertain tax positions |  | 3.8 |  |  | 0.4 |  |  | (0.3) |
Change in valuation allowances |  | 2.1 |  |  | (9.8) |  |  | (0.8) |
U.S. income tax benefit |  | (0.6) |  |  | — |  |  | — |
Other |  | 0.1 |  |  | — |  |  | — |
Enacted rate changes |  | — |  |  | — |  |  | (17.1) |
Provision (benefit) for income taxes |  | $ | 79.3 |  |  | $ | 42.3 |  |  | $ | (11.9) |
The tax effects of temporary differences and carryforwards that give rise to significant portions of deferred tax assets and liabilities were as follows:
As of December 31, |  | 2023 |  | 2022
Deferred tax assets |  |  |  |
Tax loss carryforwards |  | $ | 813.0 |  |  | $ | 825.5 |
Postretirement benefits |  | 183.0 |  |  | 149.6 |
Foreign tax credit carryforwards |  | 83.6 |  |  | 109.2 |
Other tax credit carryforwards |  | 29.1 |  |  | 32.7 |
Deferred revenue |  | 31.9 |  |  | 28.2 |
Employee benefits and compensation |  | 31.5 |  |  | 21.2 |
Purchased capitalized software |  | 19.4 |  |  | 16.9 |
Depreciation |  | 33.0 |  |  | 32.6 |
Warranty, bad debts and other reserves |  | 7.6 |  |  | 7.1 |
Capitalized costs |  | 9.0 |  |  | 6.2 |
Other |  | 57.6 |  |  | 49.9 |
|  | 1,298.7 |  |  | 1,279.1 |
Valuation allowance |  | (1,150.1) |  |  | (1,110.5) |
Total deferred tax assets |  | $ | 148.6 |  |  | $ | 168.6 |
Deferred tax liabilities |  |  |  |
Capitalized research and development |  | $ | 10.4 |  |  | $ | 31.0 |
Other |  | 25.1 |  |  | 29.2 |
Total deferred tax liabilities |  | $ | 35.5 |  |  | $ | 60.2 |
Net deferred tax assets |  | $ | 113.1 |  |  | $ | 108.4 |
Changes in the valuation allowance was as follows:
Year ended December 31, |  | 2023 |  | 2022 |  | 2021
Valuation allowance, at beginning of year |  | $ | (1,110.5) |  |  | $ | (1,226.2) |  |  | $ | (1,271.5) |
Actuarial pension adjustments |  | 84.5 |  |  | 70.7 |  |  | 99.5 |
Expired net operating losses/tax credits |  | 42.9 |  |  | 52.3 |  |  | 50.0 |
Foreign exchange |  | (6.8) |  |  | 14.8 |  |  | 18.4 |
Recognition of income tax benefit (expense) (i) |  | (125.9) |  |  | (43.9) |  |  | (102.1) |
Other |  | (34.3) |  |  | 21.8 |  |  | (20.5) |
Valuation allowance, at end of year |  | $ | (1,150.1) |  |  | $ | (1,110.5) |  |  | $ | (1,226.2) |
(i) Includes U.S. pension activity of $(95.9) million, ($11.3) million and ($84.9) million for the years ended December 31, 2023, 2022 and 2021, respectively. The company has tax effected tax loss carryforwards as follows:
As of December 31, |  | 2023
U.S. Federal |  | $ | 366.0 |
State and local |  | 180.2 |
Foreign |  | 266.8 |
Total tax loss carryforwards |  | $ | 813.0 |
These carryforwards will expire as follows:
Year |
2024 | $ | 13.4 |
2025 | 20.8 |
2026 | 15.6 |
2027 | 40.8 |
2028 | 93.1 |
Thereafter | 358.2 |
Unlimited | 271.1 |
Total | $ | 813.0 |
The company also has available tax credit carryforwards, which will expire as follows:
Year |
2024 | $ | 22.5 |
2025 | 20.7 |
2026 | 33.7 |
2027 | 9.1 |
2028 | 0.3 |
Thereafter | 26.4 |
Total | $ | 112.7 |
A full valuation allowance is currently maintained for all U.S. and certain foreign deferred tax assets in excess of deferred tax liabilities. The company will record a tax provision or benefit for those international subsidiaries that do not have a full valuation allowance against their net deferred tax assets. Any profit or loss recorded for the company’s U.S. operations will have no provision or benefit associated with it due to such valuation allowance, except with respect to withholding taxes not creditable against future taxable income. As a result, the company’s provision or benefit for taxes may vary significantly depending on the geographic distribution of income. The realization of the company’s net deferred tax assets as of December 31, 2023, is primarily dependent on the ability to generate sustained taxable income in various jurisdictions. Judgment is required to estimate forecasted future taxable income, which may be impacted by future business developments, actual results, strategic operational and tax initiatives, legislative, and other economic factors and developments. Any increase or decrease in the valuation allowance would result in additional or lower income tax expense in that period and could have a significant impact on that period’s earnings. During 2023, the company determined that a portion of its non-U.S. net deferred tax assets required an additional valuation allowance. The net change in the valuation allowance impacting the effective tax rate in 2023 was approximately $2.1 million, primarily in Latin America. During 2022, the company determined that a portion of its non-U.S. net deferred tax assets no longer required a valuation allowance. The net change in the valuation allowances impacting the effective tax rate in 2022 was approximately $9.8 million of a tax benefit, primarily in the United Kingdom and other foreign jurisdictions. Under U.S. tax law, distributions from foreign subsidiaries to U.S. shareholders are generally exempt from taxation. Consequently, the deferred income tax liability on undistributed earnings is generally limited to any foreign withholding or other foreign taxes that will be imposed on such distributions. As the company currently intends to indefinitely reinvest the earnings of certain foreign subsidiaries, no provision has been made for income taxes that may become payable upon distribution of the earnings of such subsidiaries. The unrecognized deferred income tax liability at December 31, 2023 approximated $32.2 million. Cash paid for income taxes, net of refunds was as follows:
Year ended December 31, |  | 2023 |  | 2022 |  | 2021
Cash paid for income taxes, net of refunds |  | $ | 63.4 |  |  | $ | 49.0 |  |  | $ | 53.7 |
A reconciliation of the beginning and ending amount of unrecognized tax benefits is as follows:
Year ended December 31, |  | 2023 |  | 2022 |  | 2021
Balance at January 1 |  | $ | 17.8 |  |  | $ | 21.6 |  |  | $ | 30.9 |
Additions based on tax positions related to the current year |  | 4.6 |  |  | 1.9 |  |  | 3.5 |
Changes for tax positions of prior years |  | 2.6 |  |  | 1.2 |  |  | (8.8) |
Reductions as a result of a lapse of applicable statute of limitations |  | (4.6) |  |  | (5.4) |  |  | (2.6) |
Settlements |  | — |  |  | — |  |  | (0.3) |
Changes due to foreign currency |  | 0.5 |  |  | (1.5) |  |  | (1.1) |
Balance at December 31 |  | $ | 20.9 |  |  | $ | 17.8 |  |  | $ | 21.6 |
The company recognizes penalties and interest accrued related to income tax liabilities in the provision for income taxes in its consolidated statements of income (loss). At December 31, 2023 and 2022, the company had an accrual of $4.6 million and $3.8 million, respectively, for the payment of penalties and interest. At December 31, 2023, all of the company’s liability for unrecognized tax benefits, if recognized, would affect the company’s effective tax rate. Within the next 12 months, the company believes that it is reasonably possible that the amount of unrecognized tax benefits may decrease by $1.3 million related to a statute of limitation expiration; however, various events could cause this belief to change in the future. The company and its subsidiaries file income tax returns in the U.S. federal jurisdiction, and various states and foreign jurisdictions. The company is currently undergoing audits in several of its foreign jurisdictions. Ongoing income tax audits throughout the world are not expected to have a material impact on the company’s financial position. Internal Revenue Code Sections 382 and 383 provide annual limitations with respect to the ability of a corporation to utilize its net operating loss (as well as certain built-in losses) and tax credit carryforwards, respectively (Tax Attributes), against future U.S. taxable income, if the corporation experiences an “ownership change.” In general terms, an ownership change may result from transactions increasing the ownership of certain stockholders in the stock of a corporation by more than 50 percentage points over a three-year period. The company regularly monitors ownership changes (as calculated for purposes of Section 382). The company has determined that, for purposes of the rules of Section 382 described above, an ownership change occurred in 2011. Any future transaction or transactions and the timing of such transaction or transactions could trigger additional ownership changes under Section 382. As a result of the ownership change in 2011, utilization for certain of the company’s Tax Attributes, U.S. net operating losses and tax credits, is subject to an overall annual limitation of $70.6 million. The cumulative limitation as of December 31, 2023, is approximately $488 million. This limitation will be applied to any net operating losses and then to any other Tax Attributes. Any unused limitation may be carried over to later years. Based on presently available information and the existence of tax planning strategies, the company does not expect to incur a U.S. federal cash tax liability in the near term.

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