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WYNDHAM WORLDWIDE CORPORATION

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2010 2009<br />

Non-current deferred income tax assets:<br />

Net operating loss carryforwards $ 52 $ 53<br />

Foreign tax credit carryforward 41 67<br />

Alternative minimum tax credit carryforward 71 44<br />

Tax basis differences in assets of foreign subsidiaries 71 79<br />

Accrued liabilities and deferred income 27 18<br />

Other comprehensive income 40 32<br />

Other 3 19<br />

Depreciation and amortization 4 17<br />

Valuation allowance (*)<br />

(34) (50)<br />

Non-current deferred income tax assets<br />

Non-current deferred income tax liabilities:<br />

275 279<br />

Depreciation and amortization 585 547<br />

Installment sales of vacation ownership interests 703 869<br />

Other 8 —<br />

Non-current deferred income tax liabilities 1,296 1,416<br />

Non-current net deferred income tax liabilities $ 1,021 $ 1,137<br />

(*)<br />

During 2010, the Company’s valuation allowance was reduced by $32 million, primarily due to the current utilization of certain cumulative foreign<br />

tax credits, which the Company was able to realize based on certain changes in its tax profile.<br />

As of December 31, 2010, the Company’s net operating loss carryforwards primarily relate to state net<br />

operating losses which are due to expire at various dates, but no later than 2030. No provision has been made for<br />

U.S. federal deferred income taxes on $323 million of accumulated and undistributed earnings of certain foreign<br />

subsidiaries as of December 31, 2010 since it is the present intention of management to reinvest the undistributed<br />

earnings indefinitely in those foreign operations. The determination of the amount of unrecognized U.S. federal<br />

deferred income tax liability for unremitted earnings is not practicable.<br />

The Company’s effective income tax rate differs from the U.S. federal statutory rate as follows for the year<br />

ended December 31:<br />

2010 2009 2008<br />

Federal statutory rate 35.0% 35.0% 35.0%<br />

State and local income taxes, net of federal tax benefits 1.3 1.7 (1.9)<br />

Taxes on foreign operations at rates different than U.S. federal statutory rates (1.0) (0.9) 1.6<br />

Taxes on foreign income, net of tax credits 1.0 1.9 (1.2)<br />

Foreign tax credits (3.6) — —<br />

IRS examination settlement (1.8) — —<br />

Other 1.8 2.9 (2.2)<br />

Goodwill impairment — — (52.4)<br />

32.7% 40.6% (21.1)%<br />

The Company’s effective tax rate declined from 40.6% in 2009 to 32.7% in 2010 primarily due to the benefit<br />

derived from the current utilization of certain cumulative foreign tax credits, which the Company was able to realize<br />

based on certain changes in its tax profile, as well as the settlement of the IRS examination. The difference between<br />

the Company’s 2009 effective tax rate of 40.6% and 2008 effective tax rate of (21.1%) is primarily due to the<br />

absence of impairment charges recorded during 2008, a charge recorded during 2009 for the reduction of deferred<br />

tax assets and the origination of deferred tax liabilities in a foreign tax jurisdiction and the write-off of deferred tax<br />

assets that were associated with stock-based compensation, which were in excess of the Company’s pool of excess<br />

tax benefits available to absorb tax deficiencies.<br />

F-21

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