Annual report pursuant to Section 13 and 15(d)

Income Taxes

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Income Taxes
 12 Months Ended
Dec. 31, 2023
Income Tax Disclosure [Abstract]  
Income Taxes Income Taxes
The sources of Earnings before income taxes were as follows:
(in millions) 2023 2022 2021
United States $ 364.4  $ 603.2  $ 537.0 
Foreign 264.5  250.4  199.4 
Earnings before income taxes $ 628.9  $ 853.6  $ 736.4 

The Income tax provision consisted of the following:
(in millions) 2023 2022 2021
Current tax expense:
U.S. Federal $ 88.7  $ 109.8  $ 84.3 
State and local 17.3  20.3  11.2 
Foreign 73.9  61.1  67.3 
Total current 179.9  191.2  162.8 
Deferred tax expense (benefit):
U.S. Federal 17.2  (24.6) (4.9)
State and local 10.2  1.5  (5.9)
Foreign (11.0) 4.2  (11.0)
Total deferred 16.4  (18.9) (21.8)
Income tax provision $ 196.3  $ 172.3  $ 141.0 
Temporary differences and carryforwards giving rise to deferred tax assets and liabilities as of December 31, 2023 and 2022 are summarized in the table below:
(in millions) 2023 2022
Deferred tax assets:
Loss carryforwards $ 59.9  $ 56.8 
Tax credit carryforwards 56.1  52.9 
Deferred revenue 38.0  36.3 
Product warranties 35.4  33.6 
Sales incentives and discounts 33.3  29.2 
Operating lease liabilities 29.8  24.4 
Interest expense 17.6  18.0 
Equity compensation 13.1  13.5 
Other 73.2  66.2 
Gross deferred tax assets 356.4  330.9 
Valuation allowance (71.3) (52.8)
Deferred tax assets 285.1  278.1 
Deferred tax liabilities:
Depreciation and amortization (54.5) (81.7)
Operating lease assets (27.6) (21.8)
State and Local income taxes (22.7) (22.7)
Other (5.9) (9.3)
Deferred tax liabilities (110.7) (135.5)
Total net deferred tax assets $ 174.4  $ 142.6 

As of December 31, 2023, the Company had a total valuation allowance against its deferred tax assets of $71.3 million. The remaining realizable value of deferred tax assets as of December 31, 2023 was determined by evaluating the potential to recover the value of these assets through the utilization of tax loss and credit carrybacks, the reversal of existing taxable temporary differences and carryforwards, certain tax planning strategies and future taxable income exclusive of reversing temporary differences and carryforwards. As of December 31, 2023, the Company retained valuation allowance reserves of $50.2 million against deferred tax assets in the U.S. primarily related to state tax credits that are subject to restrictive rules for future utilization, various state operating loss carryforwards, and non-amortizable intangibles and valuation allowances of $21.1 million for deferred tax assets related to foreign jurisdictions, primarily Luxembourg.

As of December 31, 2023, the tax benefit of loss carryforwards totaling $60.3 million was available to reduce future tax liabilities. This deferred tax asset was comprised of $1.1 million for the tax benefit of federal net operating loss (NOL) carryforwards, $24.0 million for the tax benefit of state NOL carryforwards and $35.2 million for the tax benefit of foreign NOL carryforwards. NOL carryforwards of $43.1 million expire at various intervals between the years 2024 and 2043, while $17.2 million have an unlimited life.

As of December 31, 2023, tax credit carryforwards totaling $56.1 million were available to reduce future tax liabilities. This deferred tax asset was comprised of $6.6 million related to federal tax credits, $48.4 million of various state tax credits related to research and development, capital investment and job incentives and $1.1 million related to foreign tax credits. These tax credit carryforwards expire at various intervals between the years 2024 and 2042.
No deferred income taxes have been provided as of December 31, 2023 or 2022 on the applicable undistributed earnings of the non-U.S. subsidiaries where the indefinite reinvestment assertion has been applied. If at some future date these earnings cease to be indefinitely reinvested and are repatriated, the Company may be subject to additional U.S. income taxes and foreign withholding and other taxes on such amounts. Remittances from foreign subsidiaries are generally not subject to U.S. income taxation. These remittances are either excluded from U.S. taxable income as earnings that have already been subjected to taxation or in the alternative are subject to a 100 percent foreign dividends received deduction. The Company continues to provide deferred taxes, primarily related to foreign withholding taxes, on the undistributed net earnings of foreign subsidiaries and unconsolidated affiliates that are not deemed to be indefinitely reinvested in operations outside the United States, although such amounts were immaterial as of December 31, 2023 and 2022. We have not provided for deferred taxes on the outside basis differences in our investments in our foreign subsidiaries. A determination of the unrecognized deferred taxes related to these outside basis differences is not practicable.

As of December 31, 2023, 2022 and 2021 the Company had $9.3 million, $7.8 million and $10.1 million of gross unrecognized tax benefits, including interest, respectively. Substantially all of these amounts, if recognized, would impact the Company's tax provision and the effective tax rate.

The Company recognizes interest and penalties related to unrecognized tax benefits in income tax expense. As of December 31, 2023, 2022 and 2021, the amounts accrued for interest and penalties were not material.

The following is a reconciliation of the total amounts of unrecognized tax benefits excluding interest and penalties for the 2023, 2022 and 2021 annual reporting periods:
(in millions) 2023 2022 2021
Balance as of January 1 $ 7.5  $ 9.7  $ 3.7 
Gross increases - tax positions prior periods 0.9  0.5  5.9 
Gross decreases - tax positions prior periods —  (2.1) (0.2)
Gross increases - current period tax positions —  —  0.5 
Decreases - settlements with taxing authorities —  (0.6) (0.2)
Balance as of December 31 $ 8.4  $ 7.5  $ 9.7 

The Company believes it is reasonably possible that the total amount of gross unrecognized tax benefits as of December 31, 2023 could decrease by approximately $2.1 million in 2024 due to settlements with taxing authorities or lapses in applicable statutes of limitation. Due to the various jurisdictions in which the Company files tax returns and the uncertainty regarding the timing of the settlement of tax audits, it is possible that there could be significant changes in the amount of unrecognized tax benefits in 2024, but the amount cannot be estimated at this time.

The Company is regularly audited by federal, state and foreign tax authorities. The Internal Revenue Service (IRS) has completed its field examination and has issued its Revenue Agents Report through the 2014 tax year and all open issues have been resolved. The Company is currently open to tax examinations by the IRS for the 2020 through 2022 tax years. The Company is open to state and local tax audits in major tax jurisdictions dating back to the 2017 taxable year. The Company is no longer subject to income tax examinations by any major foreign tax jurisdiction for years prior to 2015.

Many countries are implementing local legislation based upon the Organization for Economic Co-operation and Development’s base erosion and profit shifting project, the Pillar Two framework, which imposes a global minimum corporate tax rate of 15%. The Company will continue to monitor the implementation of the Pillar Two rules in the jurisdictions in which it operates.
The difference between the actual income tax provision and the tax provision computed by applying the statutory Federal income tax rate to Earnings before income taxes is attributable to the following:
(in millions) 2023 2022 2021
Income tax provision at 21 percent $ 132.1  $ 179.3  $ 154.6 
State and local income taxes, net of federal income tax effect 13.3  19.5  18.0 
Deferred tax asset valuation allowance 17.8  (10.4) (24.2)
Equity compensation (1.3) (2.9) (1.8)
Change in estimates related to prior years and prior years amended tax return filings 1.8  (1.3) 3.5 
Federal and state tax credits (15.2) (16.6) (14.9)
Taxes related to foreign income, net of credits (4.5) 12.1  5.5 
Deferred tax reassessment 2.5  6.4  6.4 
FDII deduction (16.6) (18.4) (15.3)
Intercompany sales of intellectual property rights 53.1  —  — 
Nondeductible loss on intercompany sale 6.9  —  — 
Other 6.4  4.6  9.2 
Actual income tax provision $ 196.3  $ 172.3  $ 141.0 
Effective tax rate 31.2  % 20.2  % 19.1  %

For the year ended December 31, 2023, the Company recorded $17.8 million of income tax expense related to an increase in its valuation allowance on deferred tax assets and $53.1 million of income tax expense related to the intercompany sales of intellectual property (IP) rights. The valuation allowance increase is primarily due to certain federal tax credits, impairment of certain investments, and state credits and NOLs that may not be realized in future years. The sales of the IP rights were to better align the ownership of these rights with how our business operates.

During 2021, the Company recorded a $21.0 million income tax benefit related to the release of a portion of the Company’s valuation allowance. This was due to a reassessment of the realizability of certain federal tax credits, state tax credits and state NOLs. The conclusion to release the valuation allowance was based upon sustained positive operating performance of its U.S. operations and the availability of expected future taxable income, leading the Company to believe that it is more likely than not that the benefit of these U.S. deferred tax assets will be realized.