evaluation of each uncertain tax position requires management to apply specialized skill, knowledge, and significant judgment related to the identified position. The Company’s liability for unrecognized tax benefits and related accrued interest and penalties as of December 31, 2021 was $580 million and $502 million, respectively. Because of the complexity of tax laws, regulations and legal interpretations relevant to numerous taxing jurisdictions in which the Company operates, auditing uncertain tax positions and the determination of whether the more likely than not threshold was met requires a high degree of auditor judgment and increased extent of effort, including the involvement of our income tax specialists. How the Critical Audit Matter Was Addressed in the Audit Our audit procedures related to uncertain tax positions included the following, among others: • We tested the effectiveness of internal controls over income taxes, including those over identifying uncertain tax positions and measuring liabilities. • We evaluated, with the assistance of our income tax specialists, the Company’s uncertain tax positions by performing the following: – Obtaining Company and third-party opinions or memoranda regarding the uncertain tax positions. – Identifying key judgements underlying the Company’s position and evaluating whether the conclusions are consistent with our interpretation of the relevant laws and regulations. – Evaluating the Company’s method of measuring its liability for unrecognized tax benefits, including underlying data and assumptions. – Evaluating the basis for certain intercompany transactions, such as transfer pricing, by comparison to economic studies performed by management and third-party data. – Evaluating matters raised by taxing authorities in former and ongoing tax audits. – Assessing changes and interpretation of applicable tax law. /s/ DELOITTE & TOUCHE LLP Midland, Michigan February 4, 2022 We have served as the Company's auditor since 1905. 70
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