## Table

|  |  | Year Ended March 31, |  |
|---|---|---|---|
|  | 2019 | 2018 | 2017 |
| Pretax (loss) income: |  |  |  |
| U.S. | $(593.4) | $(127.3) | $(279.3) |
| Foreign | 797.9 | 864.6 | 369.1 |
|  | $204.5 | $737.3 | $89.8 |
| Current (benefit) expense: |  |  |  |
| U.S. Federal | $(98.0) | $369.4 | $21.3 |
| State | (5.3) | 0.5 | 1.0 |
| Foreign | 14.1 | 60.8 | 23.8 |
| Total current (benefit) expense | $(89.2) | $430.7 | $46.1 |
| Deferred expense (benefit): |  |  |  |
| U.S. Federal | $11.9 | $82.5 | $(114.7) |
| State | 0.6 | 0.1 | (5.4) |
| Foreign | (74.7) | (31.4) | (6.8) |
| Total deferred (benefit) expense | (62.2) | 51.2 | (126.9) |
| Total Income tax (benefit) provision | $(151.4) | $481.9 | $(80.8) |



## Text

Note 11. Income Taxes


The income tax provision consists of the following (amounts in millions):


On December 22, 2017, the Tax Cuts and Jobs Act (the "Act") was enacted into law. The Act provides for numerous significant tax law changes and modifications including the reduction of the U.S. federal corporate income tax rate from 35.0% to 21.0%, the requirement for companies to pay a one-time transition tax on earnings of certain foreign subsidiaries that were previously tax deferred and the creation of new taxes on certain foreign-sourced earnings.


Accounting Standards Codification ("ASC") 740, Income Taxes, requires companies to recognize the effect of the tax law changes in the period of enactment. However, the SEC staff issued Staff Accounting Bulletin ("SAB") 118, which allowed companies to record provisional amounts during a measurement period that is similar to the measurement period used when accounting for business combinations. The Company recorded a reasonable estimate when measurable and with the understanding that the provisional amount was subject to further adjustments under SAB 118. In addition, for significant items for which the Company could not make a reasonable estimate, no provisional amounts were recorded. As of December 31, 2018, the Company completed its review of the previously recorded provisional amounts related to the Act, recorded necessary adjustments, and the amounts are now final under SAB 118.


As of March 31, 2018, the Company remeasured certain deferred tax assets and liabilities based on the rates at which they were expected to reverse in the future (which was generally 21%), by recording a provisional income tax benefit of $136.7 million. Upon further analysis of certain aspects of the Act and refinement of its calculations during the period ended December 31, 2018, the Company did not make adjustments to the provisional amount


The one-time transition tax is based on the Company's total post-1986 earnings and profits (E&P), the tax on which the Company previously deferred from U.S. income taxes under U.S. law. The Company recorded a provisional amount for its one-time transition tax expense for each of its foreign subsidiaries, resulting in a transition tax expense of $644.7 million at March 31, 2018. Upon further analyses of the Act and notices and regulations issued and proposed by the U.S. Department of the Treasury and the Internal Revenue Service, the Company finalized its calculations of the transition tax expense during the period ended December 31, 2018. The Company increased its March 31, 2018 provisional amount by $13.1 million to $657.8 million, which is included as a component of income tax expense from continuing operations. The measurement period adjustment of $13.1 million decreased basic and diluted net income per common share by $0.06 and $0.05, respectively, for the year ended March 31, 2019.


The Company intends to invest substantially all of its foreign subsidiary earnings, as well as its capital in its foreign subsidiaries, indefinitely outside of the U.S. in those jurisdictions in which the Company would incur significant, additional costs upon repatriation of such amounts. It is not practical to estimate the additional tax that would be incurred, if any, if the permanently reinvested earnings were repatriated.