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58 Jarden Corporation Annual Report 2013
The following table sets forth the details and the activity related to unrecognized tax benet as of and for the years ended
December31, 2013 and 2012:
(In millions) 2013 2012
Unrecognized tax benets, January1, $68.3 $52.9
Increases (decreases):
Acquisitions 3.5 0.6
Tax positions taken during the current period 27.6 16.8
Tax positions taken during a prior period (2.7)—
Settlements with taxing authorities (7.7)(3.8)
Other (0.1)1.8
Unrecognized tax benets, December31, $88.9 $68.3
During 2013 and 2012, the change in the unrecognized tax benets primarily relates to tax positions taken during the current period and
tax settlements made during the year. At December31, 2013, the amount of gross unrecognized tax benets that, if recognized, would
affect the reported tax rate is $92.6. The Company has indemnication for $4.8 of the gross unrecognized tax benet from the sellers
of acquired companies.
It is likely that the total amount of unrecognized tax benets will increase in the next 12 months. Such increase will occur as a result of
the Company’s tax return position with respect to the utilization of tax attributes and the conclusion of ongoing tax audits in various
jurisdictions around the world. While one or more of these events is reasonably possible to occur within the next 12 months, the
Company is not able to accurately estimate the range of the change in the unrecognized tax benets that will result. The calculation
of unrecognized tax benets involves dealing with uncertainties in the application of complex global tax regulations. Management
regularly assesses the Company’s tax positions in light of legislative, bilateral tax treaties, regulatory and judicial developments in the
countries in which the Company does business.
The Company conducts business globally and, as a result, the Company or its subsidiaries le income tax returns in the U.S. federal
jurisdiction, and in various state, local, and foreign jurisdictions. In the normal course of business, the Company or its subsidiaries
are subject to examination by tax authorities throughout the world, including such major jurisdictions as Canada, France, Germany,
Hong Kong, Hungary, India, Italy, Japan, Malaysia, Peru and U.S., state and local jurisdictions. As of December31, 2013, the Company
remains subject to examination by federal and state tax authorities for the tax years 2005 to 2012. At December31, 2013, certain of the
Company’s more signicant foreign jurisdictions remain subject to examination for various tax years between 2000 and 2012.
The Company classies all interest expense and penalties on uncertain tax positions as income tax expense. The provision for income
taxes for 2013, 2012 and 2011 includes tax-related interest expense of $1.7, $2.4 and $1.1, respectively. As of December31, 2013 and 2012,
the liability for tax-related interest expense was $8.6 and $6.8, respectively.
Notes to Consolidated Financial Statements
Jarden Corporation Annual Report 2013 (Dollars in millions, except per share data and unless otherwise indicated)