Mirion Technologies, Inc. Annual report pursuant to Section 13 and 15(d)

Annual report pursuant to Section 13 and 15(d)

Income Taxes (Tables)

Income Taxes (Tables)

12 Months Ended

Dec. 31, 2023

Schedule of Income Before Income Tax Domestic and Foreign Current and Deferred Portions of Income Tax Benefits

The domestic and foreign components of (loss) before provision for income taxes and the provision for income taxes were as follows (in millions):


	Successor
	Fiscal Year Ended December 31, 2023		Fiscal Year Ended December 31, 2022		From October 20, 2021 through December 31, 2021
United States	$	(125.0)	$	(169.5)	$	(26.8)
Foreign	19.7		(137.1)		(3.0)
Net loss before benefit from income taxes	$	(105.3)	$	(306.6)	$	(29.8)
Income tax provision (benefit):
Current:
Federal	$	8.6	$	—	$	—
State and local	2.0		2.9		0.8
Foreign	13.7		16.1		3.8
Total current provision	$	24.3	$	19.0	$	4.6
Deferred:
Federal	$	(17.6)	$	(19.6)	$	(5.4)
State and local	(5.5)		(4.2)		(1.2)
Foreign	(7.8)		(13.4)		(4.8)
Total deferred benefit	$	(30.9)	$	(37.2)	$	(11.4)
Total benefit from income taxes	$	(6.6)	$	(18.2)	$	(6.8)


	Predecessor
	From July 1, 2021 through October 19, 2021		Fiscal Year Ended June 30, 2021
United Kingdom	$	(41.2)	$	(125.3)
United States	(61.2)		(53.8)
Other foreign	(8.9)		14.8
Net loss before benefit from income taxes	$	(111.3)	$	(164.3)
Income tax provision (benefit):
Current:
United Kingdom	$	0.1	$	0.3
United States	1.4		2.4
Other foreign	2.0		9.4
Total current provision	$	3.5	$	12.1
Deferred:
United Kingdom	$	—	$	—
United States	(7.0)		(15.5)
Other foreign	(2.1)		(2.5)
Total deferred benefit	$	(9.1)	$	(18.0)
Total benefit from income taxes	$	(5.6)	$	(5.9)

Schedule of Effective Income Tax Rate Reconciliation

The provision (benefit) for income taxes differs from the amount computed by applying the U.S. Federal statutory income tax rate to loss before provision for income taxes as follows:


	Successor
	Fiscal Year Ended December 31, 2023		Fiscal Year Ended December 31, 2022		From October 20, 2021 through December 31, 2021
Income tax at U.S. Federal statutory rate	21.0	%	21.0	%	21.0	%
State and local taxes, net of federal impact	2.4	%	0.3	%	1.7	%
Foreign tax rate differential	(1.5)	%	(0.5)	%	0.3	%
U.S. tax on foreign earnings, net of foreign tax credits	(2.2)	%	(0.9)	%	—	%
State and local tax legislative changes	1.3	%	0.6	%	—	%
Research and development tax credits	1.7	%	0.5	%	0.2	%
U.S. foreign derived intangible income deduction	3.5	%	—	%	—	%
Change in valuation allowance	(9.0)	%	(1.4)	%	3.2	%
Unrecognized tax benefits	(2.2)	%	(0.2)	%	0.1	%
Stock-based compensation expense	(3.2)	%	(1.9)	%	(3.7)	%
Warrant liability change in fair value	(5.5)	%	2.8	%	0.9	%
Goodwill impairment	—	%	(14.5)	%	—	%
Other	—	%	0.1	%	(0.9)	%
Total effective income tax rate	6.3	%	5.9	%	22.8	%

The provision (benefit) for income taxes differs from the amount computed by applying the U.K. statutory income tax rate to loss before provision for income taxes as follows:


	Predecessor
	From July 1, 2021 through October 19, 2021		Fiscal Year Ended June 30, 2021
Income tax at U.K. Federal statutory rate	19.0	%	19.0	%
U.S. tax on foreign earnings, net of foreign tax credits	(0.3)	%	(0.9)	%
Foreign taxes, including U.S.	0.5	%	(1.3)	%
Transaction costs	(3.4)	%	(1.4)	%
Change in valuation allowance	(1.5)	%	3.8	%
Unrecognized tax benefits	(0.9)	%	(0.7)	%
Nondeductible interest expense	(6.9)	%	(14.4)	%
Stock-based compensation expense	(1.6)	%	—	%
Other	0.1	%	(0.5)	%
Total effective income tax rate	5.0	%	3.6	%

Schedule of Deferred Tax Assets and Liabilities

The components of the Company’s net deferred tax assets and liabilities consist of the following (in millions):


	Successor
	December 31, 2023		December 31, 2022
Deferred tax assets:
Net operating loss carryforwards	$	19.1	$	19.0
Federal and state credit carryforwards	4.4		10.5
Property, plant and equipment	0.6		0.5
Deferred and other revenue differences	7.5		7.8
Interest carryforwards	23.2		19.1
Other reserves and accrued expenses	18.4		14.9
Lease liabilities	8.7		11.1
Derivatives	5.4		2.9
Other assets	7.7		5.0
Capitalized research and development	10.1		5.6
Total deferred tax assets	105.1		96.4
Less: valuation allowance	(30.0)		(23.9)
	$	75.1	$	72.5


	Successor
	December 31, 2023		December 31, 2022
Deferred tax liabilities:
Purchased technologies and other intangibles	$	(122.2)	$	(153.4)
Deferred and other revenue differences	(13.9)		(7.4)
Property, plant and equipment	(11.9)		(15.0)
Lease right of use assets	(8.2)		(10.2)
Other liabilities	(2.9)		(2.8)
Total deferred tax liabilities	(159.1)		(188.8)
Net deferred tax liabilities	$	(84.0)	$	(116.3)

Summary of Valuation Allowance


	Successor						Predecessor
	Fiscal Year Ended December 31, 2023		Fiscal Year Ended December 31, 2022		From October 20, 2021 through December 31, 2021		From July 1, 2021 through October 19, 2021		Fiscal Year Ended June 30, 2021
Valuation allowance balance – beginning of period	$	23.9	$	20.7	$	1.0	$	29.1	$	29.0
Increases/(decreases) resulting from the Mirion Business Combination	—		(0.4)		19.7		—		—
Increases resulting from other business combinations	—		—		—		—		0.5
Other increases	9.8		5.3		—		1.6		8.6
Other decreases	(3.7)		(1.7)		—		—		(9.0)
Valuation allowance balance – end of period	$	30.0	$	23.9	$	20.7	$	30.7	$	29.1

Summary of Income Tax Contingencies

A reconciliation of the beginning and ending amount of unrecognized tax benefits is as follows (in millions):


	Successor						Predecessor
	Fiscal Year Ended December 31, 2023		Fiscal Year Ended December 31, 2022		From October 20, 2021 through December 31, 2021		From July 1, 2021 through October 19, 2021		Fiscal Year Ended June 30, 2021
Balance, beginning of period	$	6.9	$	6.6	$	—	$	5.0	$	0.8
Increases resulting from the Mirion Business Combination	—		1.4		6.5		—		—
Current year additions to positions	2.7		1.3		0.1		1.5		2.6
Additions from other business combinations					0.2		—		1.7
Lapse of applicable statute of limitations	(0.2)		(0.4)		—		—		(0.1)
Reductions to prior year positions	(1.0)		(2.0)		(0.2)		—		—
Foreign currency translation adjustments	—		—		—		—		—
Balance, end of period	$	8.4	$	6.9	$	6.6	$	6.5	$	5.0

Schedule of Open Tax Years by Major Jurisdictions

In many cases, the Company’s uncertain tax positions are related to tax years that remain subject to examination by tax authorities. The following describes open tax years by major tax jurisdictions as of December 31, 2023:


			Years Open
Jurisdiction:
Canada			2015 – 2023
France			2021 – 2023
Germany			2017 – 2023
United Kingdom			2017 – 2023
United States—Federal			2017 – 2023
United States—State			2005 – 2023