XML 52 R14.htm IDEA: XBRL DOCUMENT v2.4.0.8
INCOME TAXES
6 Months Ended
Jul. 31, 2013
INCOME TAXES [Abstract]  
INCOME TAXES
9.  INCOME TAXES

The Company recorded income tax expense of $0.9 million and $0.3 million in the second quarter of fiscal 2014 and 2013, respectively. The effective tax rate increased to 42% during the second quarter of fiscal 2014 compared to 26% for the same period in the prior year. The increase in overall tax rate for the second quarter of fiscal 2014 is primarily due to a significant equity compensation shortfall. A shortfall is a result of stock-based compensation expense recorded in the financial statements being greater than the tax deduction generated by the exercise of SARs and the vesting of RSUs.
 
The Company recorded income tax expense of $0.6 million and $1.9 million in the first six months of fiscal 2014 and 2013, respectively. The effective tax rate increased to 101% from 40% for the same period in the prior year, due to a significant decline in income during the first six months of fiscal 2014 and due to the impact of the equity compensation shortfall discussed above.

The Company continues to benefit from operating in foreign locations, such as Ireland, due to the lower statutory income tax rate relative to the U.S. federal and state tax rate. This benefit is significantly reduced by withholding taxes and foreign base company sales and services income that is taxed both in the U.S. and in the foreign jurisdiction.
 
The total amount of unrecognized tax benefits was $2.6 million at July 31, 2013. The entire amount of unrecognized tax benefits, if recognized, will impact the Company's effective tax rate. This liability is classified as long-term unless the liability is expected to conclude within twelve months of the reporting date. In the next twelve months, due to potential settlements with domestic tax authorities related to tax credits, an estimated $0.2 million of unrecognized tax benefits may be recognized.

The Company's policy is to recognize interest and penalties, if any, related to unrecognized tax benefits as a component of income tax expense. As of July 31, 2013, the Company has accrued approximately $0.2 million of interest and penalty expense relating to unrecognized tax benefits.

In August 2013, the Company received new information from the Franchise Tax Board related to the audit of its fiscal year 2004 and fiscal year 2005 California research and development tax credit. Pursuant to Financial Accounting Standards Board Accounting Standards Codification ("ASC") 740 "Income Taxes", paragraph ASC 740-10-25-8, only information that is available at the reporting date is considered in the recognition and measurement analysis for purposes of uncertain tax positions. A change in available facts subsequent to an enterprise's reporting date, but before issuance of the financial statements, should be recognized in the period in which the change in facts occurs, even if that new information provides a better estimate of the ultimate outcome of an uncertainty. As a result, the Company may record a non-cash charge to income tax expense of up to $2.6 million in the third quarter of fiscal 2014.

The Company files U.S. federal, state, and foreign tax returns that are subject to audit by various tax authorities. The Company is currently under audit in India for fiscal years ended March 31, 1998, 1999, 2006, 2008, 2009, 2010 and 2011 and in California for fiscal years ended 2004 and 2005. It is also under audit in South Africa and Thailand for the fiscal year ended 2012.