|12 Months Ended|
Dec. 31, 2022
|Income Tax Disclosure [Abstract]|
INCOME TAX PROVISION
Consolidated income from operations before income taxes consisted of the following:
The components of the provision for income taxes consisted of the following:
The following is a reconciliation of the statutory federal income tax rate to the effective rate reported in the financial statements:
DEFERRED INCOME TAX BALANCES
Significant components of the Company's deferred taxes consisted of the following:
The Company had foreign net operating loss carryforwards of $64.3 million as of December 31, 2022, all of which has an unlimited carryforward period. As of December 31, 2022 and 2021, the net operating losses result in deferred tax assets of $18.8 million and $22.8 million, respectively, and were subject to a valuation allowance of $18.8 million and $20.2 million, respectively.
As of December 31, 2022, the Company had accumulated undistributed earnings generated by the Company's foreign subsidiaries of $422.9 million. As a result of the Tax Cuts and Jobs Act, these earnings have been subject to U.S. tax, so any further taxes associated with such earnings would generally be limited to foreign withholding and state taxes. The Company has recorded a deferred tax liability for these, except in the jurisdictions where the Company intends to indefinitely reinvest the earnings.
UNRECOGNIZED TAX BENEFITS
The Company conducts business globally and, as a result, the Company or one or more of its subsidiaries file income tax returns in the United States federal jurisdiction and various state and foreign jurisdictions. The Company is subject to examination by taxing authorities throughout the world, including such major jurisdictions as Canada, China, France, Japan, South Korea, Switzerland, and the United States. The Company has effectively settled Canadian tax examinations of all years through 2012, United States tax examinations of all years through 2018, Japanese tax examinations of all years through 2019, France tax examinations of all years through 2016, Swiss tax examinations of all years through 2019, Italy tax examinations of all years through 2016, and China tax examinations of all years through 2018. The Korean National Tax Service concluded an audit of the Company's 2009 through 2013 corporate income tax returns in 2014, an audit of the Company's 2014 corporate income tax return in 2016, and an audit of 2016 through 2020 corporate income tax returns in 2022. Due to the nature of the findings in the 2009 through 2014 audits, the Company has invoked the Mutual Agreement Procedures outlined in the United States-Korean income tax treaty. The Company does not anticipate that adjustments relative to these findings, or any other ongoing tax audits, will result in material changes to its financial condition, results of operations or cash flows. As of December 31, 2022, the
Company was under audit in Canada for tax year 2018. Other than the findings and audits previously noted, the Company is not currently under examination in any other major jurisdiction.
A reconciliation of the beginning and ending amount of gross unrecognized tax benefits is as follows:
Due to the potential for resolution of income tax audits currently in progress, and the expiration of various statutes of limitation, it is reasonably possible that the unrecognized tax benefits balance may change within the twelve months following December 31, 2022 by a range of zero to $2.4 million. Open tax years, including those previously mentioned, contain matters that could be subject to differing interpretations of applicable tax laws and regulations as they relate to the amount, timing, or inclusion of revenue and expenses or the sustainability of income tax credits for a given examination cycle.
Unrecognized tax benefits of $9.2 million, $12.9 million and $13.6 million would affect the effective tax rate if recognized as of December 31, 2022, 2021 and 2020, respectively.The Company recognizes interest expense and penalties related to income tax matters in Income tax expense. The Company recognized a net decrease of accrued interest and penalties of $0.8 million in 2022, and a net increase of accrued interest and penalties of $0.3 million in 2021 and a net increase of accrued interest and penalties of $0.8 million in 2020, all of which related to uncertain tax positions. The Company had $1.8 million and $2.6 million of accrued interest and penalties related to uncertain tax positions as of December 31, 2022 and 2021, respectively.
The entire disclosure for income taxes. Disclosures may include net deferred tax liability or asset recognized in an enterprise's statement of financial position, net change during the year in the total valuation allowance, approximate tax effect of each type of temporary difference and carryforward that gives rise to a significant portion of deferred tax liabilities and deferred tax assets, utilization of a tax carryback, and tax uncertainties information.
Reference 1: http://www.xbrl.org/2003/role/disclosureRef