ManpowerGroup 2014 Annual Report Download - page 74

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Notes to Consolidated Financial Statements
We have recorded a deferred tax asset of $129.7 as of December 31, 2014, for the benefit of these net operating losses.
Realization of this asset is dependent on generating sufficient taxable income prior to the expiration of the loss carryforwards.
A related valuation allowance of $103.4 has been recorded as of December 31, 2014, as management believes that
realization of certain net operating loss carryforwards is unlikely.
Pretax earnings of non-United States operations was $485.9, $298.1 and $234.6 in 2014, 2013 and 2012, respectively.
We have not provided United States income taxes or non-United States withholding taxes on $733.0 of unremitted earnings
of non-United States subsidiaries that are considered to be permanently invested. Deferred taxes are provided on $452.8
of unremitted earnings of non-United States subsidiaries that may be remitted to the United States. As of December 31,
2014 and 2013, we have recorded a deferred tax liability of $53.1 and $16.7, respectively, related to these non-United States
earnings that may be remitted.
As of December 31, 2014, we had gross unrecognized tax benefits related to various tax jurisdictions, including interest and
penalties, of $30.8. We have related tax benefits of $1.4, and the net amount of $29.4 would favorably affect the effective
tax rate if recognized. We do not expect our unrecognized tax benefits to change significantly over the next year.
As of December 31, 2013, we had gross unrecognized tax benefits related to various tax jurisdictions, including interest and
penalties, of $32.3. We had related tax benefits of $1.9 for a net amount of $30.4.
We recognize accrued interest and penalties related to unrecognized tax benefits in income tax expense. We recorded a
benefit of $0.6 related to our net interest and penalties during 2014, and accrued net interest and penalties of $6.3 and
$0.1 during 2013 and 2012, respectively.
The following table summarizes the activity related to our unrecognized tax benefits during 2014, 2013 and 2012:
2014 2013 2012
Gross unrecognized tax benefits, beginning of year $ 23.9 $ 26.4 $ 25.0
Increases in prior year tax positions 0.7 2.1 5.8
Decreases in prior year tax positions (1.2) (5.6) (0.8)
Increases for current year tax positions 2.2 3.4 3.1
Expiration of statute of limitations and audit settlements (2.6) (2.4) (6.7)
Gross unrecognized tax benefits, end of year $ 23.0 $ 23.9 $ 26.4
Potential interest and penalties 7.8 8.4 2.1
Balance, end of year $ 30.8 $ 32.3 $ 28.5
We conduct business globally in 80 countries and territories. We are routinely audited by the tax authorities of the various
tax jurisdictions in which we operate. Generally, the tax years that could be subject to examination are 2008 through 2014
for our major operations in Germany, Italy, France, Japan, the United States and the United Kingdom. As of December 31,
2014, we were subject to tax audits in France, Germany, Denmark, Austria, Italy, Norway and Spain. We believe that the
resolution of these audits will not have a material impact on earnings.
NOTES TO CONSOLIDATED FINANCIAL STATEMENTS
in millions, except share and per share data