Provision for Income Taxes (Tables)
|
12 Months Ended |
Dec. 31, 2016 |
| Income Tax Disclosure [Abstract] |
|
| Components of Income (Loss) Before Income Taxes |
The components of income (loss) before income taxes are as
follows:
|
|
|
|
|
|
|
|
|
|
|
|
|
| |
|
2016 |
|
|
2015 |
|
|
2014 |
|
|
Netherlands
|
|
|
537 |
|
|
|
1,528 |
|
|
|
398 |
|
|
Foreign
|
|
|
(1,140 |
) |
|
|
(42 |
) |
|
|
241 |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
(603 |
) |
|
|
1,486 |
|
|
|
639 |
|
|
| Components of Benefit (Provision) for Income Taxes |
The components of the benefit (provision) for income taxes are as
follows:
|
|
|
|
|
|
|
|
|
|
|
|
|
| |
|
2016 |
|
|
2015 |
|
|
2014 |
|
|
Current taxes:
|
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|
|
|
|
|
|
|
|
|
|
|
|
Netherlands
|
|
|
(7 |
) |
|
|
(13 |
) |
|
|
(7 |
) |
|
Foreign
|
|
|
(67 |
) |
|
|
(51 |
) |
|
|
(32 |
) |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
(74 |
) |
|
|
(64 |
) |
|
|
(39 |
) |
|
Deferred taxes:
|
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|
|
|
|
|
|
|
|
|
|
|
|
Netherlands
|
|
|
205 |
|
|
|
(4 |
) |
|
|
2 |
|
|
Foreign
|
|
|
720 |
|
|
|
172 |
|
|
|
(3 |
) |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
925 |
|
|
|
168 |
|
|
|
(1 |
) |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Total benefit (provision) for income taxes
|
|
|
851 |
|
|
|
104 |
|
|
|
(40 |
) |
|
| Reconciliation of Statutory Income Tax Rate |
A reconciliation of the statutory income tax rate in the
Netherlands as a percentage of income (loss) before income taxes
and the effective income tax rate is as follows:
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|
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|
| (in percentages) |
|
2016 |
|
|
2015 |
|
|
2014 |
|
|
Statutory income tax in the Netherlands
|
|
|
25.0 |
|
|
|
25.0 |
|
|
|
25.0 |
|
|
|
|
|
|
Rate differential local statutory rates versus statutory rate
of the Netherlands
|
|
|
24.2 |
|
|
|
(4.3 |
) |
|
|
(2.5 |
) |
|
Net change in valuation allowance
|
|
|
72.6 |
|
|
|
(13.8 |
) |
|
|
2.4 |
|
|
Prior year adjustments
|
|
|
0.1 |
|
|
|
— |
|
|
|
0.5 |
|
|
Non-taxable income
|
|
|
1.7 |
|
|
|
(0.1 |
) |
|
|
(0.3 |
) |
|
Non-deductible expenses/losses
|
|
|
(7.0 |
) |
|
|
4.0 |
|
|
|
5.6 |
|
|
Sale of non-deductible goodwill
|
|
|
— |
|
|
|
2.7 |
|
|
|
— |
|
|
Other taxes and tax rate changes
|
|
|
7.1 |
|
|
|
1.0 |
|
|
|
— |
|
|
Tax effects of remitted and unremitted earnings and withholding
taxes
|
|
|
(2.7 |
) |
|
|
0.1 |
|
|
|
1.3 |
|
|
Tax on gains related to internal corporate reorganization
transactions
|
|
|
(10.3 |
) |
|
|
— |
|
|
|
— |
|
|
Unrecognized tax benefits
|
|
|
(0.5 |
) |
|
|
0.1 |
|
|
|
0.6 |
|
|
Netherlands tax incentives
|
|
|
17.9 |
|
|
|
(18.5 |
) |
|
|
(21.5 |
) |
|
Foreign tax incentives
|
|
|
13.0 |
|
|
|
(3.2 |
) |
|
|
(4.8 |
) |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Effective tax rate
|
|
|
141.1 |
% |
|
|
(7.0 |
%) |
|
|
6.3 |
% |
|
| Principal Components of Deferred Tax Assets and Liabilities |
The principal components of deferred tax assets and liabilities are
presented below:
|
|
|
|
|
|
|
|
|
| |
|
2016 |
|
|
2015 |
|
|
Operating loss and tax credit carryforwards
|
|
|
1,031 |
|
|
|
963 |
|
|
Accrued interest
|
|
|
432 |
|
|
|
545 |
|
|
Other accrued liabilities
|
|
|
107 |
|
|
|
147 |
|
|
Pensions
|
|
|
86 |
|
|
|
87 |
|
|
Stock Based Compensation
|
|
|
58 |
|
|
|
73 |
|
|
Restructuring
|
|
|
40 |
|
|
|
61 |
|
|
Receivables
|
|
|
36 |
|
|
|
11 |
|
|
Inventories (including purchase accounting basis difference)
|
|
|
27 |
|
|
|
(109 |
) |
|
Other assets
|
|
|
10 |
|
|
|
9 |
|
|
Long-term debt
|
|
|
— |
|
|
|
179 |
|
|
|
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|
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|
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|
Total Gross Deferred Tax Assets
|
|
|
1,827 |
|
|
|
1,966 |
|
|
Valuation Allowance
|
|
|
(127 |
) |
|
|
(632 |
) |
|
|
|
|
|
|
|
|
|
|
Total Net Deferred Tax Assets
|
|
|
1,700 |
|
|
|
1,334 |
|
|
Intangible assets (including purchase accounting basis
difference)
|
|
|
(2,431 |
) |
|
|
(2,952 |
) |
|
Undistributed earnings of foreign subsidiaries
|
|
|
(367 |
) |
|
|
(359 |
) |
|
Property, plant and equipment (including purchase accounting basis
difference)
|
|
|
(134 |
) |
|
|
(226 |
) |
|
|
|
|
|
|
|
|
|
|
Total Deferred Tax Liabilities
|
|
|
(2,932 |
) |
|
|
(3,537 |
) |
|
|
|
|
|
|
|
|
|
|
Net Deferred Tax Position
|
|
|
(1,232 |
) |
|
|
(2,203 |
) |
|
| Classification of Deferred Tax Assets and Liabilities in Consolidated Balance Sheets |
The classification of the deferred tax assets and liabilities in
the Company’s consolidated balance sheets is as follows:
|
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|
|
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|
|
|
| |
|
2016 |
|
|
2015 |
|
|
Deferred tax assets within other current assets
|
|
|
— |
|
|
|
26 |
|
|
Deferred tax assets within other non-current assets
|
|
|
427 |
|
|
|
69 |
|
|
Deferred tax liabilities within accrued liabilities
|
|
|
— |
|
|
|
(5 |
) |
|
Deferred tax liabilities within non-current liabilities
|
|
|
(1,659 |
) |
|
|
(2,293 |
) |
|
|
|
|
|
|
|
|
|
|
|
|
(1,232 |
) |
|
|
(2,203 |
) |
|
| Expiration of Tax Loss Carryforwards |
At December 31, 2016 tax loss carryforwards of
$1,899 million (inclusive of $270 million of U.S. state tax
losses) will expire as follows:
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| |
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Balance |
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| |
|
December 31, |
|
|
Scheduled expiration |
|
| |
|
2016 |
|
|
2017 |
|
|
2018 |
|
|
2019 |
|
|
2020 |
|
|
2021 |
|
|
2022-2026 |
|
|
later |
|
|
unlimited |
|
|
Tax loss carryforwards
|
|
|
1,899 |
|
|
|
26 |
|
|
|
10 |
|
|
|
29 |
|
|
|
10 |
|
|
|
1 |
|
|
|
947 |
|
|
|
290 |
|
|
|
586 |
|
|
| Expiration of Tax Credit Carryforwards |
The Company also has tax credit carryforwards of $749 million
(excluding the effect of unrecognized tax benefits), which are
available to offset future tax, if any, and which will expire as
follows:
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| |
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Balance
December 31,
2016 |
|
|
|
|
| |
|
|
Scheduled expiration |
|
| |
|
|
2017 |
|
|
2018 |
|
|
2019 |
|
|
2020 |
|
|
2021 |
|
|
2022-2026 |
|
|
later |
|
|
unlimited |
|
|
Tax credit carryforwards
|
|
|
749 |
|
|
|
1 |
|
|
|
8 |
|
|
|
12 |
|
|
|
32 |
|
|
|
18 |
|
|
|
336 |
|
|
|
282 |
|
|
|
60 |
|
|
| Reconciliation of Unrecognized Tax Benefits |
A reconciliation of the beginning and ending amount of unrecognized
tax benefits is as follows:
|
|
|
|
|
|
|
|
|
|
|
|
|
| |
|
2016 |
|
|
2015 |
|
|
2014 |
|
|
Balance as of January 1,
|
|
|
149 |
|
|
|
125 |
|
|
|
143 |
|
|
Assumed in the acquisition of Freescale
|
|
|
— |
|
|
|
121 |
|
|
|
— |
|
|
Decreases from activities which are held for sale
|
|
|
(7 |
) |
|
|
— |
|
|
|
— |
|
|
Increases from tax positions taken during prior periods
|
|
|
1 |
|
|
|
1 |
|
|
|
— |
|
|
Decreases from tax positions taken during prior periods
|
|
|
(3 |
) |
|
|
(111 |
) |
|
|
(21 |
) |
|
Increases from tax positions taken during current period
|
|
|
10 |
|
|
|
15 |
|
|
|
3 |
|
|
Decreases relating to settlements with the tax authorities
|
|
|
(4 |
) |
|
|
(2 |
) |
|
|
— |
|
|
|
|
|
|
|
|
|
|
|
|
|
|
|
Balance as of December 31,
|
|
|
146 |
|
|
|
149 |
|
|
|
125 |
|
|