General Motors 2014 Annual Report Download - page 119

GENERAL MOTORS COMPANY AND SUBSIDIARIES
NOTES TO CONSOLIDATED FINANCIAL STATEMENTS — (Continued)
Uncertain Tax Positions
The following table summarizes activity of the total amounts of unrecognized tax benefits (dollars in millions):
Years Ended December 31,
2014 2013 2012
Beginning balance ................................................................ $ 2,530 $ 2,745 $ 2,370
Additions to current year tax positions ................................................ 184 251 112
Additions to prior years’ tax positions ................................................. 149 276 512
Reductions to prior years’ tax positions ............................................... (603) (535) (141)
Reductions in tax positions due to lapse of statutory limitations ............................ (164) (73) (34)
Settlements ...................................................................... (138) (132) (112)
Other .......................................................................... (81) (2) 38
Ending balance ................................................................... $ 1,877 $ 2,530 $ 2,745
At December 31, 2014 and 2013 there were $1.2 billion and $1.5 billion of unrecognized tax benefits that if recognized would
favorably affect our effective tax rate in the future. In the years ended December 31, 2014, 2013 and 2012 income tax related interest
and penalties were insignificant. At December 31, 2014 and 2013 we had liabilities of $246 million and $286 million for income tax
related interest and penalties.
In the year ended December 31, 2013 we remeasured a previously disclosed uncertain tax position and recorded a $473 million tax
benefit that increased net operating loss carryforwards, reducing future taxable income.
At December 31, 2014 it is not possible to reasonably estimate the expected change to the total amount of unrecognized tax benefits
in the next twelve months.
Other Matters
Income tax returns are filed in multiple jurisdictions and are subject to examination by taxing authorities throughout the world. We
have open tax years from 2006 to 2014 with various significant tax jurisdictions. These open years contain matters that could be
subject to differing interpretations of applicable tax laws and regulations as they relate to the amount, character, timing or inclusion of
revenue and expenses or the sustainability of income tax credits for a given audit cycle. Given the global nature of our operations
there is a risk that transfer pricing disputes may arise.
We have net operating loss carryforwards in Germany through November 30, 2009 that, as a result of reorganizations that took
place in 2008 and 2009, were not recorded as deferred tax assets. Depending on the outcome of European court decisions these loss
carryforwards may be available to reduce future taxable income in Germany.
General Motors Corporation was liquidated on December 15, 2011. The Internal Revenue Service has audited the returns through the
liquidation date and, in January 2014, the audit of these returns was closed. The reduction to the amount of unrecognized tax benefits was
not significant.
In January 2013 the U.S. Congress enacted federal income tax legislation including an extension of the research credit for tax years
2012 and 2013. As a result, in the year ended December 31, 2013 we recorded an income tax benefit related to the 2012 research
credit of approximately $200 million.
Note 19. Restructuring and Other Initiatives
We have executed various restructuring and other initiatives and we plan to execute additional initiatives in the future, if necessary,
in order to align manufacturing capacity and other costs with prevailing global automotive production and to improve the utilization
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