DIRECTV 2012 Annual Report Download - page 103

DIRECTV
NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS—(continued)
No income tax provision has been made for the portion of undistributed We recorded interest and penalties accrued related to unrecognized tax benefits
earnings of foreign subsidiaries, excluding Venezuela, deemed permanently of $12 million in 2012, $16 million in 2011 and $21 million in 2010 in ‘‘Income
reinvested that amounted to approximately $11 million in 2012. It is not tax expense’’ in the Consolidated Statements of Operations. We have accrued, as
practicable to determine the amount of the unrecognized deferred tax liability part of our liability for unrecognized tax benefits, interest and penalties of
related to the investments in these foreign subsidiaries. $32 million as of December 31, 2012, and $67 million as of December 31, 2011.
A reconciliation of the beginning and ending balances of the total amounts of We file numerous consolidated and separate income tax returns in the U.S.
gross unrecognized tax benefits is as follows: federal jurisdiction and in many state and foreign jurisdictions. For U.S. federal tax
purposes, the tax years 2010 and 2011 remain open for examination. The
Gross Unrecognized California tax years 2001 through 2011 remain open to examination and the
Tax Benefits income tax returns in the other state and foreign tax jurisdictions in which we have
(Dollars in Millions) operations are generally subject to examination for a period of three to five years
Balance as of January 1, 2010 ...................... $527 after filing of the respective return.
Increases in tax positions for prior years .............. 7
Decreases in tax positions for prior years .............. (207) We engage in continuous discussions and negotiations with federal, state, and
Increases in tax positions for the current year ........... 35 foreign taxing authorities and reevaluate our uncertain tax positions, and, while it is
often difficult to predict the final outcome or the timing of resolution of any
Balance as of December 31, 2010 .................... 362
particular tax matter or tax position, we believe that it is reasonably possible that
Increases in tax positions for prior years .............. 17
our unrecognized tax benefits could decrease by up to approximately $40 million
Decreases in tax positions for prior years .............. (4)
during the next twelve months.
Increases in tax positions for the current year ........... 15
Balance as of December 31, 2011 .................... 390 Note 13: Capital Lease Obligations
Decreases in tax positions for prior years .............. (6)
Increases in tax positions for the current year ........... 35 We include the current and noncurrent portions of the present value of the
Expiration of the statute of limitations ............... (141) net minimum lease payments under capital leases for satellites and vehicles in
‘‘Accounts payable and accrued liabilities’’ and ‘‘Other liabilities and deferred
Balance as of December 31, 2012 .................... $278 credits’’ in the Consolidated Balance Sheets. The following table sets forth the
present value of the net minimum lease payments under capital leases for satellites
As of December 31, 2012, our unrecognized tax benefits totaled $278 million,
including $227 million of tax positions the recognition of which would affect the
annual effective income tax rate. The decrease in the unrecognized tax benefits is
primarily attributable to the expiration of the statute of limitations in federal and
foreign tax jurisdictions.
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