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Income Taxes
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3 Months Ended |
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Mar. 30, 2013
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| Income Tax Disclosure [Abstract] | |
| Income Taxes |
Note 14 – Income Taxes
The Company recognized an income tax provision from continuing operations for the three months ended March 30, 2013 of $21.9 million, which included a net charge of $11.1 million associated with valuation allowance adjustments primarily related to stock-based compensation. The Company recognized an income tax provision from continuing operations of $10.9 million for the three months ended March 31, 2012, which included a net charge of $1.0 million associated with valuation allowance adjustments primarily related to stock-based compensation. The effective tax rate from continuing operations, which is calculated as the income tax benefit or provision as a percentage of pretax income, for the three months ended March 30, 2013 and March 31, 2012 was 28.5 percent and 18.8 percent, respectively.
The Company continues to adjust its valuation allowances as deferred tax assets increase or decrease, resulting in effectively no recorded tax benefit for those jurisdictions with operating losses, or no tax expense for those jurisdictions with operating income and loss carryforwards. However, an income tax provision or benefit is still recorded for those entities that are not in a cumulative loss position.
In certain jurisdictions, the Company is in a cumulative three-year loss position, which is significant negative evidence when evaluating the realizability of its deferred tax assets. Consequently, the Company has substantially reserved its deferred tax assets in the applicable jurisdictions. This negative evidence continues to outweigh the positive evidence of profitability in 2011, 2012 and the first three months of 2013, thereby requiring the Company to continue to maintain full valuation allowances for certain entities in the first quarter of 2013. It is possible, if the Company's operating results continue to improve, the Company will be out of a cumulative three-year loss position in 2013 and will evaluate the need to maintain these valuation reserves against the deferred tax assets. It is possible that a significant portion of the Company's March 30, 2013 valuation allowance balances could be reversed by the end of 2013.
As of March 30, 2013 and December 31, 2012, the Company had $24.1 million and $27.8 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 March 30, 2013, could decrease by approximately $16.0 million in the next 12 months due to settlements with taxing authorities or lapses in the 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 other significant changes in the amount of unrecognized tax benefits in 2013, but the amount cannot be estimated.
The Company recognizes interest and penalties related to unrecognized tax benefits in income tax expense. As of March 30, 2013 and December 31, 2012, the Company had approximately $3.2 million and $3.1 million accrued for the payment of interest, respectively. There were no amounts accrued for penalties at March 30, 2013 and December 31, 2012.
The Company is regularly audited by federal, state and foreign tax authorities. The Company's taxable years 2009 through 2011 are currently open for examination by the Internal Revenue Service (IRS). The IRS has completed its field examination and has issued its Revenue Agents Report for 2006 through 2009 and all open issues have been resolved. 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 2004 taxable year. With the exception of Germany, where the Company is currently under audit for the taxable years 2002 through 2007, the Company is no longer subject to income tax examinations by any other major foreign tax jurisdiction for years prior to 2007.
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