Blackberry 2014 Annual Report Download - page 113

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BlackBerry Limited
Notes to the Consolidated Financial Statements
In millions of United States dollars, except share and per share data, and except as otherwise indicated
24
reinvest the cumulative earnings of its foreign subsidiaries. As a result, $32 million relating to future withholding taxes
was accrued as a deferred tax liability.
The Company’s total unrecognized income tax benefits as at March 1, 2014 and March 2, 2013 were $8 million and $29
million, respectively. A reconciliation of the beginning and ending amount of unrecognized income tax benefits that, if
recognized, would affect the Company’s effective income tax rate is as follows:
March 1, 2014 March 2, 2013 March 3, 2012
Unrecognized income tax benefits, opening balance $ 29 $ 146 $ 164
Increase for income tax positions of prior years 5 9 15
Increase for income tax positions of current year — 2 —
Settlement of tax positions (23)(152)(8)
Expiration of statute of limitations — — (24)
Other (3) 24 (1)
Unrecognized income tax benefits, ending balance $ 8 $ 29 $ 146
As at March 1, 2014, all of the unrecognized income tax benefits of $8 million have been netted against deferred income
tax assets on the Company’s consolidated balance sheets in accordance with ASU 2013-11. See Note 2 for details on ASU
2013-11.
A summary of open tax years by major jurisdiction is presented below:
Jurisdiction
Canada(1) Fiscal 2009 - 2014
United States(2) Fiscal 2012 - 2014
United Kingdom Fiscal 2011 - 2014
_______________
(1) Includes federal as well as provincial and state jurisdictions, as applicable.
(2) Pertains to federal tax years. Certain state jurisdictions remain open from fiscal 2010 through fiscal 2014.
The Company is subject to ongoing examination by tax authorities in the jurisdictions in which it operates. The Company
regularly assesses the status of these examinations and the potential for adverse outcomes to determine the adequacy of
the provision for income taxes as well as the provisions for indirect and other taxes and related penalties and interest. The
Company believes it is reasonably possible that approximately $5 million of its gross unrecognized income tax benefit
will be realized in the next twelve months. While the final resolution of these audits is uncertain, the Company believes
the ultimate resolution of these audits will not have a material adverse effect on its consolidated financial position,
liquidity or results of operations.
The Company recognizes interest and penalties related to unrecognized income tax benefits as interest expense that is
netted and reported within investment income (loss). The amount of interest accrued as at March 1, 2014 was
approximately $1 million (March 2, 2013 – approximately $6 million). The amount of penalties accrued as at March 1,
2014 was nominal (March 2, 2013 – nominal).