12. Income Taxes

Our effective tax rates for the periods presented were as follows:

Six Months Ended

October 30,

2015

October 24,

2014

Effective tax rates

31.1

28.8

Our effective tax rates reflect the impact of a significant amount of our earnings being taxed in foreign jurisdictions at rates below the U.S. statutory tax rate. In addition, our effective tax rates for the six months ended October 30, 2015 and October 24, 2014 were impacted by adjustments related to income tax audits as discussed below.

In June 2015, the Internal Revenue Service (IRS) signed a closing agreement on transfer pricing arrangements and, in October 2015, completed the examination of our fiscal 2008 to 2010 income tax returns. During the three and six months ended October 30, 2015, we recorded discrete charges of $10 million and $23 million, respectively, attributable to transfer pricing and other audit settlements and the related re-measurement of uncertain tax positions for tax years subject to future audits.

In July 2014, the IRS completed the examination of our fiscal 2005 to 2007 income tax returns upon approval by the Joint Committee of Taxation. During the six months ended October 24, 2014, we recorded a discrete charge of $47 million attributable to the audit settlements and related re-measurements of uncertain tax positions for tax years subject to future audits.

In October 2014, the United Kingdom’s tax authority concluded the examination of our fiscal 2009 to 2012 UK income tax returns. We recorded a $1 million income tax benefit for the net impact of the audit adjustments and related release of uncertain tax positions.

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

	Six Months Ended
	October 30, 2015			October 24, 2014
Balance at beginning of period	$	272		$	236
Additions based on tax positions related to the current year		7			13
Additions for tax positions of prior years		20			99
Decreases for tax positions of prior years		(38	)		(19	)
Settlements		(52	)		(54	)
Balance at end of period	$	209		$	275

As of October 30, 2015, we had $209 million of gross unrecognized tax benefits, of which $158 million has been recorded in other long-term liabilities. Unrecognized tax benefits of $148 million, including penalties, interest and indirect benefits, would affect our provision for income taxes if recognized.

We are currently undergoing income tax audits in the United States (U.S.) and several foreign tax jurisdictions. Transfer pricing calculations are key issues under audits in various jurisdictions, and are often subject to dispute and appeals. The IRS has concluded the examination of our income tax returns for our fiscal years through 2010. We expect the IRS to commence the examination of subsequent years within the next twelve months.

On September 17, 2010, the Danish Tax Authorities issued a decision concluding that distributions declared in 2005 and 2006 from our Danish subsidiary were subject to Danish at-source dividend withholding tax. We do not believe that our Danish subsidiary is liable for withholding tax and filed an appeal with the Danish Tax Tribunal to that effect. On December 19, 2011, the Danish Tax Tribunal issued a ruling that our Danish subsidiary was not liable for Danish withholding tax. The Danish tax examination agency appealed to the Danish High Court in March 2012. The Danish High Court hearing has not yet occurred.

We continue to monitor the progress of ongoing discussions with tax authorities and the impact, if any, of the expected expiration of the statute of limitations in various taxing jurisdictions.

On July 27, 2015, in Altera Corp. v. Commissioner, the U.S. Tax Court issued an opinion related to the treatment of stock-based compensation expense in an intercompany cost-sharing arrangement. A final decision has yet to be issued by the Tax Court due to other outstanding issues related to the case. At this time, the U.S. Department of the Treasury has not withdrawn the requirement to include stock-based compensation from its regulations. Due to the uncertainty surrounding the status of the current regulations, questions related to the scope of potential benefits, and the risk of the Tax Court’s decision being overturned upon appeal, we have not recorded any benefit as of October 30, 2015. We will continue to monitor ongoing developments and potential impacts to our financial statements.