First Data 2013 Annual Report Download - page 112

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The following table presents the approximate amounts of federal, state and foreign net operating loss carryforwards and foreign tax credit, general
business credit and minimum tax credit carryforwards:
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 
Federal net operating loss carryforwards (a) $2,672.0
State net operating loss carryforwards (b) $ 4,228.8
Foreign net operating loss carryforwards (c) $ 2,713.2
Foreign tax credit carryforwards (d) $160.3
General business credit carryforwards (e) $11.3
Minimum tax credit carryforwards (f) $1.6
(a) If not utilized, these carryforwards will expire in years 2015 through 2033.
(b) If not utilized, these carryforwards will expire in years 2014 through 2033.
(c) Foreign net operating loss carryforwards of $143 million, if not utilized, will expire in years 2014 through 2028. The remaining foreign net operating
loss carryforwards of $2,570 million have an indefinite life.
(d) If not utilized, these carryforwards will expire in years 2018 through 2023.
(e) If not utilized, these carryforwards will expire in years 2027 through 2032.
(f) These carryforwards have an indefinite life.
In addition to the federal net operating loss carryforwards stated above, as a result of being a part of the U.S. consolidated tax return filing with First
Data Holdings, Inc., the Company is allocated another $146.1 million of net operating loss as of December 31, 2013.
The Company intends to indefinitely invest its net equity in its foreign operations, with the exception of any undistributed foreign earnings.
Accordingly, as of December 31, 2013, no provision had been made for U.S. federal and state income taxes on the cumulative amount of temporary
differences related to investments in foreign subsidiaries, other than those differences related to the undistributed earnings. Upon sale or liquidation of these
investments, the Company would potentially be subject to U.S., state and foreign income taxes and withholding taxes payable to the various foreign countries.
Determination of the amount of unrecognized deferred tax liability is not practicable because of the complexities associated with its hypothetical calculation.
A reconciliation of the unrecognized tax benefits for the year ended December 31, 2011, 2012 and 2013 is as follows:
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Balance as of January 1, 2011 $368.6
Increases for tax positions of prior years 1.3
Decreases for tax positions of prior years (28.5)
Increases for tax positions related to the current period 1.7
Decreases for cash settlements with taxing authorities (1.0)
Decreases due to the lapse of the applicable statute of limitations (7.4)
Balance as of December 31, 2011 334.7
Increases for tax positions of prior years 5.5
Decreases for tax positions of prior years (57.7)
Increases for tax positions related to the current period 6.2
Decreases for cash settlements with taxing authorities (0.1)
Decreases due to the lapse of the applicable statute of limitations (2.4)
Balance as of December 31, 2012 286.2
Increases for tax positions of prior years 3.4
Decreases for tax positions of prior years (2.9)
Increases for tax positions related to the current period 4.8
Decreases for cash settlements with taxing authorities (5.9)
Decreases due to the lapse of the applicable statute of limitations (6.1)
Balance as of December 31, 2013 $279.5
Most of the unrecognized tax benefits are included in the “Other long-term liabilities” line of the Consolidated Balance Sheets, net of the federal benefit on
state income taxes (approximately $20 million at December 31, 2013). However, those unrecognized tax benefits that affect the federal consolidated tax years
ending December 31, 2008 through December 31, 2013 are included in the “Long-term deferred tax liabilities” line of the Consolidated Balance Sheets, as these
items reduce the Company’s net operating loss and credit carryforwards from those periods. The unrecognized tax benefits as of December 31, 2013, 2012,
and 2011 included
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