XML 36 R22.htm IDEA: XBRL DOCUMENT v3.21.2
Income Taxes
12 Months Ended
Jun. 27, 2021
Income Tax Disclosure [Abstract]  
Income Taxes

14. Income Taxes

Components of Income (Loss) Before Income Taxes

The components of income (loss) before income taxes consist of the following:

 

 

 

For the Fiscal Year Ended

 

 

 

June 27, 2021

 

 

June 28, 2020

 

 

June 30, 2019

 

U.S.

 

$

(12,463

)

 

$

(74,905

)

 

$

(13,326

)

Foreign

 

 

58,810

 

 

 

18,640

 

 

 

23,337

 

Income (loss) before income taxes

 

$

46,347

 

 

$

(56,265

)

 

$

10,011

 

 

 

Components of Provision for Income Taxes

Provision for income taxes consists of the following:

 

 

 

For the Fiscal Year Ended

 

 

 

June 27, 2021

 

 

June 28, 2020

 

 

June 30, 2019

 

Current:

 

 

 

 

 

 

 

 

 

 

 

 

Federal

 

$

(577

)

 

$

282

 

 

$

(178

)

State

 

 

25

 

 

 

(118

)

 

 

28

 

Foreign

 

 

12,739

 

 

 

4,819

 

 

 

7,282

 

Total current tax expense

 

 

12,187

 

 

 

4,983

 

 

 

7,132

 

Deferred:

 

 

 

 

 

 

 

 

 

 

 

 

Federal

 

 

(1,564

)

 

 

(3,783

)

 

 

(813

)

State

 

 

131

 

 

 

116

 

 

 

1,097

 

Foreign

 

 

6,520

 

 

 

(344

)

 

 

139

 

Total deferred tax expense

 

 

5,087

 

 

 

(4,011

)

 

 

423

 

Provision for income taxes

 

$

17,274

 

 

$

972

 

 

$

7,555

 

U.S. Tax Law Change

On December 22, 2017, the U.S. government enacted comprehensive tax legislation H.R. 1, formerly known as the Tax Cuts and Jobs Act.  Fiscal 2019 includes additional benefits related to the enactment of H.R. 1 of $843.  The Global Intangible Low-Taxed Income (“GILTI”) provisions included in H.R. 1 require that certain income earned by foreign subsidiaries must be currently included in the gross income of the U.S. shareholder.  These provisions were effective for UNIFI in fiscal 2019.   UNIFI has elected to recognize GILTI as a current-period expense. Under this policy, UNIFI has not provided deferred taxes related to temporary differences that, upon their reversal, will affect the amount of income subject to GILTI in the period.

On July 20, 2020, the U.S. Treasury issued and enacted final regulations related to GILTI that allow certain U.S. taxpayers to elect to exclude foreign income that is subject to a high effective tax rate from their GILTI inclusions. The GILTI high-tax exclusion is an annual election and is retroactively available for tax years beginning after December 31, 2017. Fiscal 2021 includes a tax benefit of $4,816 related to the retroactive election.

Utilization of Net Operating Loss Carryforwards

Domestic deferred tax expense includes the utilization of federal net operating loss (“NOL”) carryforwards of $5,312, $89 and $3,122 for fiscal 2021, 2020 and 2019, respectively. Foreign deferred tax expense includes the utilization of NOL carryforwards of $441, $702 and $655 for fiscal 2021, 2020 and 2019, respectively. State deferred tax expense includes the utilization of NOL carryforwards of $167, $20 and $106 for fiscal 2021, 2020 and 2019, respectively.

Effective Tax Rate

Reconciliation from the federal statutory tax rate to the effective tax rate is as follows:

 

 

 

For the Fiscal Year Ended

 

 

 

June 27, 2021

 

 

June 28, 2020

 

 

June 30, 2019

 

Federal statutory tax rate

 

 

21.0

%

 

 

21.0

%

 

 

21.0

%

Foreign income taxed at different rates

 

 

9.0

 

 

 

(1.2

)

 

 

16.1

 

Repatriation of foreign earnings and withholding taxes

 

 

1.8

 

 

 

(2.0

)

 

 

20.3

 

U.S. tax on GILTI

 

 

3.9

 

 

 

(5.0

)

 

 

32.5

 

Change in valuation allowance

 

 

5.0

 

 

 

0.6

 

 

 

(1.5

)

Foreign tax credits

 

 

(5.4

)

 

 

0.9

 

 

 

(11.9

)

Domestic production activities deduction

 

 

0.6

 

 

 

 

 

 

(5.6

)

Research and other business credits

 

 

(3.7

)

 

 

2.0

 

 

 

(7.7

)

State income taxes, net of federal tax benefit

 

 

(0.2

)

 

 

2.6

 

 

 

(0.6

)

Change in uncertain tax positions

 

 

0.5

 

 

 

(0.3

)

 

 

8.2

 

Nondeductible compensation

 

 

1.4

 

 

 

(0.8

)

 

 

5.1

 

Nontaxable income

 

 

(2.4

)

 

 

1.1

 

 

 

(4.2

)

Valuation allowance related to loss on sale of investment in PAL

 

 

 

 

 

(19.3

)

 

 

 

Tax expense on unremitted foreign earnings

 

 

7.0

 

 

 

(0.9

)

 

 

 

Toll charge

 

 

 

 

 

 

 

 

0.7

 

Revaluation of U.S. deferred balances due to U.S. tax reform

 

 

 

 

 

 

 

 

3.1

 

Rate benefit of U.S. federal NOL carryback

 

 

(2.8

)

 

 

 

 

 

 

Deemed repatriation of foreign earnings under Subpart F

 

 

1.5

 

 

 

 

 

 

 

Nondeductible expenses and other

 

 

0.1

 

 

 

(0.4

)

 

 

 

Effective tax rate

 

 

37.3

%

 

 

(1.7

)%

 

 

75.5

%

 

 

Deferred Income Taxes

The significant components of UNIFI’s deferred tax assets and liabilities consist of the following:

 

 

 

June 27, 2021

 

 

June 28, 2020

 

Deferred tax assets:

 

 

 

 

 

 

 

 

Investments, including unconsolidated affiliates

 

$

 

 

$

3,995

 

Tax credits

 

 

18,711

 

 

 

19,457

 

Capital loss carryforwards

 

 

17,429

 

 

 

13,791

 

Accrued compensation

 

 

4,056

 

 

 

1,777

 

NOL carryforwards

 

 

3,043

 

 

 

3,907

 

Research and development costs

 

 

6,934

 

 

 

6,073

 

Other items

 

 

4,815

 

 

 

6,652

 

Total gross deferred tax assets

 

 

54,988

 

 

 

55,652

 

Valuation allowance

 

 

(36,980

)

 

 

(37,439

)

Net deferred tax assets

 

 

18,008

 

 

 

18,213

 

Deferred tax liabilities:

 

 

 

 

 

 

 

 

PP&E

 

 

(16,045

)

 

 

(17,733

)

Unremitted earnings

 

 

(3,769

)

 

 

(510

)

Recovery of non-income taxes

 

 

(3,664

)

 

 

 

Other

 

 

(8

)

 

 

(167

)

Total deferred tax liabilities

 

 

(23,486

)

 

 

(18,410

)

Net deferred tax liabilities

 

$

(5,478

)

 

$

(197

)

Deferred Income Taxes – Valuation Allowance

In assessing its ability to realize deferred tax assets, UNIFI considers whether it is more-likely-than-not that some portion or all of the deferred tax assets will not be realized.  The ultimate realization of deferred tax assets is dependent upon the generation of future taxable income during the periods in which those temporary differences become deductible.  UNIFI considers the scheduled reversal of taxable temporary differences, taxable income in carryback years, cumulative losses in recent years, projected future taxable income, and tax planning strategies in making this assessment. Since UNIFI operates in multiple jurisdictions, the assessment is made on a jurisdiction-by-jurisdiction basis, taking into account the effects of local tax law. Based on consideration of these items, management has determined that enough uncertainty exists relative to the realization of its deferred income tax asset balances to warrant the application of a full valuation allowance against the deferred tax assets of its U.S. consolidated group and certain foreign subsidiaries as of June 27, 2021.

The balances and activity for UNIFI’s deferred tax valuation allowance are as follows:

 

 

 

For the Fiscal Year Ended

 

 

 

June 27, 2021

 

 

June 28, 2020

 

 

June 30, 2019

 

Balance at beginning of year

 

$

(37,439

)

 

$

(26,020

)

 

$

(15,143

)

Decrease (increase) in valuation allowance

 

 

459

 

 

 

(11,419

)

 

 

(10,877

)

Balance at end of year

 

$

(36,980

)

 

$

(37,439

)

 

$

(26,020

)

 

Components of UNIFI’s deferred tax valuation allowance are as follows:

 

 

 

For the Fiscal Year Ended

 

 

 

June 27, 2021

 

 

June 28, 2020

 

 

June 30, 2019

 

Investments, including unconsolidated affiliates

 

$

 

 

$

(3,995

)

 

$

(5,696

)

NOL carryforwards

 

 

(2,336

)

 

 

(2,542

)

 

 

(2,943

)

Capital loss carryforwards

 

 

(17,429

)

 

 

(13,791

)

 

 

(1,105

)

Tax credits

 

 

(17,215

)

 

 

(17,111

)

 

 

(16,276

)

Total deferred tax valuation allowance

 

$

(36,980

)

 

$

(37,439

)

 

$

(26,020

)

 

During fiscal 2021, UNIFI’s valuation allowance decreased by $459. The decrease was primarily driven by a decrease in the valuation allowance on investments in unconsolidated affiliates and foreign tax credits, offset by an increase in the valuation allowance on research credits and capital loss carryforwards.

During fiscal 2020, UNIFI’s valuation allowance increased by $11,419. The increase was primarily driven by an increase in the valuation allowance on a capital loss generated by the sale of UNIFI’s interest in PAL.

During fiscal 2019, UNIFI’s valuation allowance increased by $10,877. The increase was primarily driven by an increase in the valuation allowance on foreign tax credits and certain state NOLs and credit carryforwards.  

Unrecognized Tax Benefits

A reconciliation of beginning and ending gross amounts of unrecognized tax benefits is as follows:

 

 

 

For the Fiscal Year Ended

 

 

 

June 27, 2021

 

 

June 28, 2020

 

 

June 30, 2019

 

Balance at beginning of year

 

$

1,218

 

 

$

1,083

 

 

$

166

 

Gross (decreases) increases related to current period tax positions

 

 

(24

)

 

 

98

 

 

 

26

 

Gross increases related to tax positions in prior periods

 

 

1,396

 

 

 

37

 

 

 

980

 

Gross decreases related to settlements with tax authorities

 

 

 

 

 

 

 

 

 

Gross decreases related to lapse of applicable statute of limitations

 

 

 

 

 

 

 

 

(89

)

Balance at end of year

 

$

2,590

 

 

$

1,218

 

 

$

1,083

 

 

Unrecognized tax benefits would generate a favorable impact of $2,549 on UNIFI’s effective tax rate when recognized. UNIFI does not expect material changes in uncertain tax positions within the next 12 months.  Expense for interest and penalties recognized by UNIFI within the provision for income taxes was $141, $69 and $22 for fiscal 2021, 2020 and 2019, respectively.  UNIFI had $273, $132 and $63 accrued for interest and/or penalties related to uncertain tax positions as of June 27, 2021, June 28, 2020 and June 30, 2019, respectively.

Expiration of Net Operating Loss Carryforwards and Tax Credit Carryforwards

As of June 27, 2021, UNIFI had U.S. federal capital loss carryforwards of $71,105, U.S. state NOL carryforwards of $54,361 and foreign NOL carryforwards of $5,077.  The NOL carryforwards begin expiring in varying amounts in fiscal 2022.  As of June 27, 2021, UNIFI had the following carryforward attributes held outside of the U.S. consolidated tax filing group: U.S. federal NOL carryforwards of $2,863, U.S. federal capital loss carryforwards of $4,489, and U.S. state NOL carryforwards of $15,051.  The NOL carryforwards held outside of the U.S. consolidated tax filing group began expiring in fiscal 2021.   As of June 27, 2021, UNIFI had U.S. federal foreign tax credit carryforwards of $11,213 and foreign tax credit carryforwards in foreign jurisdictions of $2,962.  The foreign tax credit carryforwards began expiring in varying amounts in fiscal 2021. As of June 27, 2021, UNIFI had U.S. federal research tax credit carryforwards of $3,964, which begin expiring in fiscal 2039.

Tax Years Subject to Examination

Unifi, Inc. and its domestic subsidiaries file a consolidated federal income tax return, as well as income tax returns in multiple state and foreign jurisdictions.  The tax years subject to examination vary by jurisdiction.  UNIFI regularly assesses the outcomes of both completed and ongoing examinations to ensure that UNIFI’s provision for income taxes is sufficient.

In fiscal 2019, the Internal Revenue Service (“IRS”) initiated an audit of UNIFI’s domestic operations for fiscal years 2016 and 2017.  In fiscal 2020, the IRS expanded the audit to include fiscal 2018.  In fiscal 2021, the IRS expanded the audit to include fiscal 2019.  Fiscal years 2009 through 2014 remain open for certain foreign tax credit amendments and net operating loss and general business credit carrybacks.

Statutes related to material foreign jurisdictions are open from January 1, 2016 and material state jurisdictions from June 24, 2018.  Certain carryforward tax attributes generated in years prior remain subject to examination and could change in subsequent tax years.

Indefinite Reinvestment Assertion

UNIFI considers $21,776 of its unremitted foreign earnings to be permanently reinvested to fund working capital requirements and operations abroad, and has therefore not recognized a deferred tax liability for the estimated future taxes that would be incurred upon repatriation. If these earnings were distributed in the form of dividends or otherwise, or if the shares of the relevant foreign subsidiaries were sold or otherwise transferred, UNIFI could be subject to additional tax liabilities of approximately $4,524.