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The Tax Cuts and Jobs Act
9 Months Ended
Apr. 30, 2019
The Tax Cuts and Jobs Act [Abstract]  
The Tax Cuts and Jobs Act

Note 17—The Tax Cuts and Jobs Act

 

On December 22, 2017, the U.S. government enacted “An Act to Provide for Reconciliation Pursuant to Titles II and V of the Concurrent Resolution on the Budget for Fiscal Year 2018”, which is commonly referred to as “The Tax Cuts and Jobs Act” (the “Tax Act”). The Tax Act reduces the U.S. federal statutory corporate tax rate from 35.0% to 21.0% effective January 1, 2018, requires companies to pay a one-time repatriation tax on earnings of certain foreign subsidiaries that were previously tax deferred (“transition tax”), and makes other changes to the U.S. income tax code. Due to the Company’s July 31 fiscal year-end, the lower corporate income tax rate is phased in, resulting in a blended U.S. federal statutory tax rate of approximately 26.9% for the Company’s fiscal 2018, and 21.0% for the Company’s fiscal years thereafter.

 

The Company has completed its accounting for the income tax effects of the Tax Act. The transition tax is based on total post-1986 earnings and profits which were previously deferred from U.S. income taxes. In fiscal 2018, the Company estimated that it will utilize $12 million of federal net operating loss carryforwards to offset the transition tax that it expects it will incur. In fiscal 2019, the Company adjusted this amount to $11 million of federal net operating loss carryforwards usage. These net operating loss carryforwards have a full valuation allowance and as such there is no impact on the Company’s results of operations.

 

The global intangible low taxed income (“GILTI”) and base erosion anti-abuse tax (“BEAT”) became effective on August 1, 2018. The Company reviewed the proposed guidance that was issued by the Internal Revenue Service in September 2018. As a result of its fully reserved net operating losses in the United States, the Company concluded there will be no material impact on its tax provision as a result of GILTI. The Company currently believes there will be no impact from the BEAT.

 

The Company anticipates that its assumptions may change as a result of future guidance and interpretation from the Internal Revenue Service, the SEC, the FASB, and various other taxing jurisdictions, and any additional adjustments will be made at that time.