Income Taxes

Income (loss) from continuing operations before income taxes is derived from (in thousands):



	Year Ended
	October 29, 2017		October 30, 2016			November 1, 2015
U.S. Domestic	$	22,464	$	(20,643	)	$	(63,205	)
International	9,749		8,248			48,065
Income (loss) from continuing operations before income tax	$	32,213	$	(12,395	)	$	(15,140	)

Income tax provision (benefit) by taxing jurisdiction consists of (in thousands):



	Year Ended
	October 29, 2017			October 30, 2016			November 1, 2015
Current:
U.S. Federal	$	(1,178	)	$	86		$	90
U.S. State and local	448			186			(1,616		)
International	3,399			2,444			5,200
Total current	$	2,669		$	2,716		$	3,674
Deferred:
U.S. Federal	$	1		$	—		$	—
U.S. State and local	721			(190		)	634
International	(3		)	(351		)	338
Total deferred	719			(541		)	972
Income tax provision	$	3,388		$	2,175		$	4,646

The difference between the income tax provision on income (loss) and the amount computed at the U.S. federal statutory rate is due to (in thousands):



	Year Ended
	October 29, 2017			October 30, 2016			November 1, 2015
U.S. Federal statutory rate	$	11,275		$	(4,338	)	$	(5,299	)
U.S. State income tax, net of U.S. Federal tax benefits	419			513			(1,435		)
International permanent differences	651			(110		)	(4,293		)
International tax rate differentials	(467		)	(1,291		)	(7,046		)
U.S. tax on international income	3,446			3,136			(1,118		)
General business credits	1,099			(4,287		)	(3,839		)
Meals and entertainment	163			209			531
Other, net	(387		)	(160		)	942
Change in valuation allowance for dispositions	(2,211		)	—			(4,237		)
Change in valuation allowance for deferred tax assets	(10,600		)	8,503			30,440
Income tax provision	$	3,388		$	2,175		$	4,646

Deferred income taxes reflect the net tax effects of temporary differences between the carrying amounts of assets and liabilities for financial reporting purposes and the amounts used for income tax purposes, and also include operating loss carryforwards. The significant components of the Company’s deferred tax assets and liabilities are as follows (in thousands):



	October 29, 2017			October 30, 2016
Deferred tax assets:
Net operating loss carryforwards	$	66,806		$	62,670
Capital loss carryforwards	5,293			21,131
U.S. federal tax credit carryforwards	48,154			47,866
Deferred income	10,251			10,714
Compensation accruals	6,276			6,170
Other, net	8,738			7,813
Total deferred tax assets	145,518			156,364
Less valuation allowance	(134,195		)	(144,863		)
Deferred tax assets, net	11,323			11,501

Deferred tax liabilities:
Unremitted earnings from foreign subsidiaries	3,453			3,356
Software development costs	6,403			5,226
Other, net	1,606			3,914
Total deferred tax liabilities	11,462			12,496
Net deferred tax asset (liability)	$	(139	)	$	(995	)

Balance sheet classification
Non-current assets	$	1,067		$	2,142
Non-current liabilities	(1,206		)	(3,137		)
Net deferred tax asset (liability)	$	(139	)	$	(995	)

At October 29, 2017, the Company has available unused U.S. federal net operating loss (“NOL”) carryforwards of $155.7 million, U.S. state NOL carryforwards of $195.2 million, international NOL carryforwards of $9.6 million and capital loss carryforwards of $13.5 million. As of October 29, 2017, the U.S. federal NOL carryforwards will expire at various dates between 2031 and 2037, the U.S. state NOL carryforwards expire at various dates between 2020 and 2037, the international NOL carryforwards expire at various dates beginning in 2018 (with some indefinite) and capital loss carryforwards expire in 2022. At October 29, 2017, the undistributed earnings of the Company’s non-U.S. subsidiaries are not intended to be permanently invested outside of the U.S. and therefore U.S. deferred taxes have been provided.

A valuation allowance has been recognized due to the uncertainty of realization of the loss carryforwards and other deferred tax assets. Beginning in fiscal 2010, the Company’s cumulative U.S. domestic and certain non-U.S. results for each three-year period were a loss. Accordingly, the Company recorded a full valuation allowance against its net U.S. domestic and certain net non-U.S. deferred tax assets as a non-cash charge to income tax expense. The three-year cumulative loss continued in fiscal 2017, 2016, and 2015 so the Company maintained a full valuation allowance against its net U.S. domestic and certain net non-U.S. deferred tax assets resulting in a total valuation allowance of $134.2 million and $144.9 million for fiscal 2017 and fiscal 2016, respectively. In reaching this conclusion, the Company considered the U.S. domestic demand and recent operating losses causing the Company to be in a three-year cumulative loss position. Management believes that the remaining deferred tax assets are more likely than not to be realized based upon consideration of all positive and negative evidence, including scheduled reversal of deferred tax liabilities and tax planning strategies determined on a jurisdiction-by-jurisdiction basis.

The Company recognizes income tax benefits for tax positions determined more likely than not to be sustained upon examination based on the technical merits of the positions. The following table sets forth the change in the accrual for uncertain tax positions, excluding interest and penalties (in thousands):



	October 29, 2017			October 30, 2016
Balance, beginning of year	$	5,237		$	5,215
Add related to current year tax provision	269			52
Reduction for tax provision of prior years - (a)	(2,973		)	—
Settlements	(993		)	—
Lapse of statute of limitations	(45		)	(30		)
Total	$	1,495		$	5,237

(a) - As a result of the sale of the quality assurance business, the parent-subsidiary relationship between the Company and Volt Canada, Inc. no longer exists and, as such, the indemnity granted at the time of sale is subject to recognition under ASC 460 by the Company. As of October 27, 2017, the Company recognized approximately $3.7 million related to the fair value of amounts accrued by Volt Canada, Inc. as of the date of the separation which are expected to be covered by the indemnity. If additional information becomes available, the Company will update the liability provision for the indemnity. This amount had previously been recognized as part of the Company’s FIN 48 liability and has been reclassified to Accrued insurance and other under ASC 460.

Of the total unrecognized tax benefits at October 29, 2017 and October 30, 2016, approximately $1.5 million and $2.5 million, respectively, would affect the Company’s effective income tax rate, if and when recognized in future years. The amount accrued for related potential interest and penalties at October 29, 2017 and October 30, 2016 was $0.2 million and $1.5 million, respectively. The Company anticipates a release of approximately $1.0 million in the first quarter of fiscal 2018, however, various events could cause the Company’s current expectations to change in the future.

The Company is subject to taxation at the federal, state and local levels in the U.S. and in various international jurisdictions. With few exceptions, the Company is generally no longer subject to examination by the U.S. federal, state, local or non-U.S. income tax authorities for years before fiscal 2004. The Company recorded a net discrete tax benefit of approximately $1.3 million resulting from the resolution of uncertain tax positions upon the completion and effective settlement of the audit of the Company’s fiscal 2004 through 2010 federal income tax returns and associated state tax audits. In March 2017, the Company received $13.8 million of federal refunds related to the completion of the audit periods. The Company continues to work with the IRS to resolve one remaining matter related to fiscal 2010 and anticipates having the matter resolved within the next several quarters.