Under Armour 2014 Annual Report Download - page 80

A
s of December 31, 2014, approximately
$
129.2 million of cash and cash equivalents was held by the
Company’s non-U.S. subsidiaries whose cumulative undistributed earnings total
$
176.8 million. Withholding and
U
.S. taxes have not been provided on the undistributed earnings as the earnings are being permanently reinvested
in its non-U.S. subsidiaries. Determining the tax liability that would arise if these earnings were repatriated is not
p
ractical.
We utilize the “with and without” method for intra
p
eriod allocation of income tax
p
rovisions. Certain tax
benefits associated with the Company’s stock-based compensation arrangements are recorded directly t
o
Stockholders’ equity including benefit from excess tax deductions
.
A
s of December 31, 2014 and 2013, the total liability for unrecognized tax benefits, including related
interest and penalties, was approximately
$
31.3 million and
$
24.1 million, respectively. The following table
r
epresents a reconciliation of the Company’s total unrecognized tax benefits balances, excluding interest an
d
p
enalties, for the years ended December 31, 2014, 2013 and 2012:
Year Ended December 31,
(
In t
h
ousan
d
s
)
20
1
4
2013 2
0
1
2
Beg
i
nn
i
ng o
f
yea
r
$
21,712
$
15,297
$
9,783
Increases as a result of tax
p
ositions taken in a
p
rior
p
eriod 2
5
0— —
Decreases as a result of tax
p
ositions taken in a
p
rior
p
eriod — — —
Increases as a result of tax positions taken during the current period 8,947 7,
5
26
5
,702
Decreases as a result of tax positions taken during the current period — — —
Decreases as a result of settlements during the current period — — —
R
eductions as a result of a lapse of statute of limitations during the curren
t
p
eriod (2,
55
6) (1,111) (188
)
End o
f
year
$
28
,
353
$
21
,
712
$
15
,
29
7
A
s of December 31, 2014,
$
26.3 million of unrecognized tax benefits, excluding interest and penalties,
wou
ld i
mpact t
h
e Company’s e
ff
ect
i
ve tax rate
if
recogn
i
ze
d
.
A
s of December 31, 2014, 2013 and 2012, the liability for unrecognized tax benefits included
$
3.0 million
,
$
2.4 million and
$
1.8 million, respectively, for the accrual of interest and penalties. For each of the years ended
December 31, 2014, 2013 and 2012, the Company recorded
$
1.2 million,
$
1.0 million and
$
0.7 million,
r
espect
i
ve
l
y,
f
or t
h
e accrua
l
o
fi
nterest an
d
pena
l
t
i
es
i
n
i
ts conso
lid
ate
d
statements o
fi
ncome. T
h
e Company
r
ecogn
i
zes accrue
di
nterest an
d
pena
l
t
i
es re
l
ate
d
to unrecogn
i
ze
d
tax
b
ene
fi
ts
i
nt
h
e prov
i
s
i
on
f
or
i
ncome taxes
o
nt
h
e conso
lid
ate
d
statements o
fi
ncome
.
T
h
e Company
fil
es
i
ncome tax returns
i
nt
h
e U.S.
f
e
d
era
lj
ur
i
s
di
ct
i
on an
d
var
i
ous state an
df
ore
i
g
n
j
ur
i
s
di
ct
i
ons. T
h
e Company
i
s current
l
yun
d
er au
di
t
b
yt
h
e Interna
l
Revenue Serv
i
ce
f
or t
h
e 2011 tax year an
db
y
t
h
e Cana
d
a Revenue Aut
h
or
i
ty
f
or t
h
e 2011 t
h
roug
h
2012 tax years. T
h
ema
j
or
i
ty o
f
t
h
e Company’s returns
f
o
r
y
ears
b
e
f
ore 2011 are no
l
onger su
bj
ect to U.S.
f
e
d
era
l
, state an
dl
oca
l
or
f
ore
i
gn
i
ncome tax exam
i
nat
i
ons
b
y tax
aut
h
or
i
t
i
es
T
h
e tota
l
amount o
f
unrecogn
i
ze
d
tax
b
ene
fi
ts re
l
at
i
ng to t
h
e Company’s tax pos
i
t
i
ons
i
ssu
bj
ect to c
h
ange
b
ase
d
on
f
uture events
i
nc
l
u
di
ng,
b
ut not
li
m
i
te
d
to, t
h
e sett
l
ements o
f
ongo
i
ng tax au
di
ts an
d
assessments an
d
t
h
e exp
i
rat
i
on o
f
app
li
ca
bl
e statutes o
fli
m
i
tat
i
ons. A
l
t
h
oug
h
t
h
e outcomes an
d
t
i
m
i
ng o
f
suc
h
events are
hi
g
hly
uncerta
i
n, t
h
e Compan
yd
oes not ant
i
c
i
pate t
h
at t
h
e
b
a
l
ance o
fg
ross unreco
g
n
i
ze
d
tax
b
ene
fi
ts, exc
l
u
di
n
gi
nteres
t
an
d
pena
l
t
i
es, w
ill
c
h
an
g
es
ig
n
ifi
cant
ly d
ur
i
n
g
t
h
e next twe
l
ve mont
h
s. However, c
h
an
g
es
i
nt
h
e occurrence,
expecte
d
outcomes, an
d
t
i
m
i
n
g
o
f
suc
h
events cou
ld
cause t
h
e Compan
y
’s current est
i
mates to c
h
an
g
e mater
i
a
lly
i
nt
h
e
f
uture
.
7
0