|3 Months Ended
Apr. 03, 2021
|Income Tax Disclosure [Abstract]
The Company recognized an income tax provision for the three months ended April 3, 2021 and March 28, 2020 of $47.4 million and $18.4 million, respectively. The income tax provision of $47.4 million included a net benefit of $3.0 million primarily associated with the net excess tax benefits related to share-based compensation and valuation allowance adjustments. The income tax provision of $18.4 million included a net benefit of $0.8 million primarily associated with the net excess tax benefits related to share-based compensation. The excess tax benefit for the three months ended April 3, 2021 and March 28, 2020 was $1.5 million and $0.5 million, respectively. The effective tax rate, which is calculated as the income tax provision as a percentage of earnings before income taxes, for the three months ended April 3, 2021 was 21.9 percent. The effective tax rate for the three months ended March 28, 2020 was 20.7 percent.
No deferred income taxes have been provided as of April 3, 2021, December 31, 2020 or March 28, 2020 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 taxes on such amounts. The Company continues to provide deferred taxes, as required, 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.
As of April 3, 2021, December 31, 2020 and March 28, 2020, the Company had $4.5 million, $4.1 million and $4.3 million of gross unrecognized tax benefits, including interest, respectively. The Company believes it is reasonably possible that the total amount of gross unrecognized tax benefits as of April 3, 2021 could decrease by approximately $0.5 million in the next 12 months due to settlements with taxing authorities or lapses in the applicable statute of limitations. 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 2021, 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 2017 through 2019 tax years. Primarily as a result of filing amended returns, which were generated by the closing of federal income tax audits, the Company is still open to state and local tax audits in major tax jurisdictions dating back to the 2014 taxable year. The Company is no longer subject to income tax examinations by any major foreign tax jurisdiction for years prior to 2013.