Income (loss) before income taxes is as follows (in thousands):


	Year Ended
	June 30,			June 30,			June 30,
	2023			2022			2021
Domestic	$	(2,179	)	$	(1,204	)	$	(4,194	)
Foreign		96,285			53,398			14,379
Income before income taxes	$	94,106		$	52,194		$	10,185

The provision for income taxes for the years ended June 30, 2023, 2022 and 2021 consisted of the following (in thousands):


	Year Ended
	June 30,			June 30,			June 30,
	2023			2022			2021
Current:
Federal	$	3,221		$	—		$	—
State		3,640			1,069			1,160
Foreign		9,086			6,460			5,334
Total current		15,947			7,529			6,494
Deferred:
Federal		368			396			324
State		433			227			1,169
Foreign		(716	)		(229	)		262
Total deferred		85			394			1,755
Provision for income taxes	$	16,032		$	7,923		$	8,249

The difference between the provision for income taxes and the amount computed by applying the federal statutory income tax rate (21 percent) to income before income taxes is explained below (in thousands):


	Year Ended
	June 30,			June 30,			June 30,
	2023			2022			2021
Tax at federal statutory rate	$	19,762		$	10,960		$	2,139
State income tax, net of federal benefit		3,003			844			917
Global intangible low-taxed income		22,721			15,470			—
US valuation allowance change – deferred tax movement		(24,682	)		(15,264	)		(9,387	)
Research and development credits		(1,503	)		(3,122	)		(2,423	)
Tax impact of foreign earnings		(5,627	)		(3,762	)		11,979
Foreign withholding taxes		1,082			1,032			828
Stock based compensation		(1,980	)		(5,011	)		1,162
Goodwill amortization		730			525			1,467
Nondeductible officer compensation		4,582			5,691			1,496
Nondeductible meals and entertainment		324			193			71
Foreign tax credits		(2,380	)		367			—
Provision for income taxes	$	16,032		$	7,923		$	8,249

Significant components of the Company’s deferred tax assets are as follows (in thousands):


	June 30,
	2023			2022
Deferred tax assets:
Net operating loss carry-forwards	$	21,553		$	51,494
Tax credit carry-forwards		57,841			70,683
Depreciation		1,899			2,093
Intangible amortization		20,652			25,725
Deferred revenue		19,698			15,928
Inventory write-downs		13,616			13,121
Other allowances and accruals		38,391			23,961
Stock based compensation		6,332			2,746
Deferred intercompany gain		3,693			3,693
Ireland goodwill amortization		4,862			5,583
Capitalization of research and development		19,062			3,813
Operating lease liability		6,303			7,203
Other		634			244
Total deferred tax assets		214,536			226,287
Valuation allowance		(195,297	)		(209,727	)
Total net deferred tax assets		19,239			16,560
Deferred tax liabilities:
Goodwill amortization		(12,471	)		(10,415	)
Operating lease right of use asset		(4,543	)		(4,656	)
Prepaid commissions		(4,899	)		(3,931	)
Deferred tax liability on foreign withholdings		(747	)		(676	)
Total deferred tax liabilities		(22,660	)		(19,678	)
Net deferred tax liabilities	$	(3,421	)	$	(3,118	)
Recorded as:
Net non-current deferred tax assets		4,326			4,599
Net non-current deferred tax liabilities		(7,747	)		(7,717	)
Net deferred tax liabilities	$	(3,421	)	$	(3,118	)

The Company’s global valuation allowance decreased by $14.4 million in the fiscal year ended June 30, 2023 and decreased by $20.9 million in the fiscal year ended June 30, 2022. The Company has provided a full valuation allowance against all of its U.S. federal and state deferred tax assets, as well as valuation allowances against certain non-U.S. deferred tax assets in Ireland and Brazil. The valuation allowance is determined by assessing both negative and positive available evidence to determine whether it is more likely than not that the deferred tax assets will be recoverable. The Company's inconsistent earnings in recent periods, including historical losses, tax attributes expiring unutilized in recent years and the cyclical nature of the Company's business provides sufficient negative evidence that require a full valuation allowance against its U.S. federal and state net deferred tax assets. The valuation allowance is evaluated periodically and can be reversed partially or in full if business results and the economic environment have sufficiently improved to support realization of the Company's deferred tax assets. During the fiscal year ended June 30, 2023, the Company has experienced a shift toward additional positive evidence, specifically the Company has achieved cumulative profits for the last three years for the first time in over 20 years.

As of June 30, 2023, the Company had net operating loss carry-forwards (“NOLs”) for U.S. federal and state tax purposes of $33.2 million and $127.3 million, respectively. As of June 30, 2023, the Company also had foreign NOLs in Australia and Brazil of $5.9 million, and $14.8 million, respectively. As of June 30, 2023, the Company also had federal and state tax credit carry-forwards of $30.5 million and $34.6 million, respectively. These credit carry-forwards consist of research and development tax credits as well as foreign tax credits. Of the $33.2 million U.S. federal NOLs carry-forwards, $19.9 million will begin to expire in the fiscal year ending June 30, 2036 and $13.4 million have an indefinite carryforward life. The state net operating losses of $127.3 million will begin to partially expire in the fiscal year ending June 30, 2024. The foreign net operating losses can generally be carried forward indefinitely. Federal research and development tax credits of $26.2 million will expire beginning in fiscal 2027, if not utilized and foreign tax credits of $4.3 million will expire beginning in fiscal 2024. North Carolina state research and development tax credits of $0.9 million will expire beginning in the fiscal year ending June 30, 2024, if not utilized. California state research and development tax credits of $33.7 million do not expire and can be carried forward indefinitely.

In June 2023, the Company performed an analysis under Section 382 of the Internal Revenue Code (“IRC”) with respect to its net operating loss and credit carry-forwards to determine whether a potential ownership change had occurred that would place a limitation on the annual utilization of these U.S. tax attributes. It was determined that no ownership change had occurred during the fiscal year ended June 30, 2022, however, it is possible a subsequent ownership change could limit the utilization of the Company's tax attributes. The Company also performed in June 2020 a separate IRC section 382 analysis with respect to the NOLs and tax credits acquired from Aerohive and have determined that while the Company will be subject to an annual limitation, the Company should not be limited on the full utilization of the losses and credits during the statutory allowable carryforward period for the NOLs and credits.

As of June 30, 2023, cumulative undistributed, indefinitely reinvested earnings of non-U.S. subsidiaries totaled $37.1 million. It has been the Company’s historical policy to invest the earnings of certain foreign subsidiaries indefinitely outside the U.S. The Company has reviewed its prior position on the reinvestment of earnings of certain foreign subsidiaries and has recorded a deferred tax liability of $0.7 million related to withholding taxes that may be incurred upon repatriation of earnings from jurisdictions where no indefinite reinvestment assertion is made. The Company continues to maintain an indefinite reinvestment assertion for earnings in certain of its foreign jurisdictions. The unrecorded deferred tax liability for potential tax associated with repatriation of these earnings as well as the deemed repatriation related to U.S. tax reform enacted in 2017 is $7.0 million.

Most recently, the United States enacted the Inflation Reduction Act in 2022, which made a number of changes to the Internal Revenue Code, including adding a 1% excise tax on stock buybacks by publicly traded corporations and a corporate minimum tax on adjusted financial statement income of certain large companies. We do not anticipate this legislation will have a material impact for the Company.

The Company conducts business globally and as a result, most of its subsidiaries file income tax returns in various domestic and foreign jurisdictions. In the normal course of business, the Company is subject to examination by taxing authorities throughout the world. Its major tax jurisdictions are the U.S., Ireland, India, California, New Hampshire, Texas and North Carolina. In general, the Company's U.S. federal income tax returns are subject to examination by tax authorities for fiscal years ended June 2003 forward due to net operating losses and the Company's state income tax returns are subject to examination for fiscal years ended June 2004 forward due to net operating losses. Statutes related to material foreign jurisdictions are generally open for fiscal years ended June 2019 forward for Ireland and for tax year ended March 2019 forward for India.

The U.S. tax rules require U.S. tax on foreign earnings, known as Global Intangible Low Taxed Income (“GILTI”). Under U.S. GAAP, taxpayers are allowed to make an accounting policy election of either (1) treating taxes due on future U.S. inclusions in taxable income related to GILTI as a current-period expense when incurred (the “period cost method”) or (2) factoring such amounts into a company’s measurement of its deferred taxes. The Company has elected to account for GILTI tax as a component of tax expense in the period in which it is incurred under the period cost method.

As of June 30, 2023, the Company had $18.3 million of unrecognized tax benefits. If fully recognized in the future, $0.2 million would impact the effective tax rate, and $18.1 million would result in adjustments to deferred tax assets and corresponding adjustments to the valuation allowance. The Company does not reasonably expect the amount of unrealized tax benefits to materially decrease during the next twelve months. The decrease in the current year related to prior year tax positions relates to the reclassification of an unrecognized tax benefit to a valuation allowance with no net impact to the financial statements.

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


Balance at June 30, 2020	$	23,897
Decrease related to prior year tax positions		(4,296	)
Increase related to prior year tax positions		28
Increase related to current year tax positions		72
Lapse of statute of limitations		(637	)
Balance at June 30, 2021	$	19,064
Decrease related to prior year tax positions		(34	)
Increase related to current year tax positions		11
Lapse of statute of limitations		(674	)
Balance at June 30, 2022	$	18,367
Decrease related to prior year tax positions		(21	)
Increase related to prior year tax positions		1
Increase related to current year tax positions		15
Lapse of statute of limitations		(65	)
Balance at June 30, 2023	$	18,297

Estimated interest and penalties related to the underpayment of income taxes, if any are classified as a component of income tax expense in the consolidated statements of operations and totaled less than $0.1 million for each of the years ended 2023, 2022 and 2021.