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Income Taxes
12 Months Ended
Jun. 30, 2015
Income Tax Disclosure [Abstract]  
Income Taxes
Income Taxes
Income before income taxes is as follows (in thousands):
 
Year Ended
 
June 30,
2015
 
June 30,
2014
 
June 30,
2013
Domestic
$
(72,176
)
 
$
(70,321
)
 
$
14,692

Foreign
5,340

 
17,200

 
(3,341
)
Total
$
(66,836
)
 
$
(53,121
)
 
$
11,351

The provision for income taxes for fiscal years 2015, 2014 and 2013 consisted of the following (in thousands): 
 
Year Ended
 
June 30,
2015
 
June 30,
2014
 
June 30,
2013
Current:
 
 
 
 
 
Federal
$
476

 
$
22

 
$
225

State
13

 
329

 
140

Foreign
2,447

 
2,987

 
1,163

Total current
2,936

 
3,338

 
1,528

Deferred:
 
 
 
 
 
Federal
1,507

 
1,632

 
15

State
103

 
76

 

Foreign
261

 
(857
)
 
135

Total deferred
1,871

 
851

 
150

Provision for income taxes
$
4,807

 
$
4,189

 
$
1,678


 The difference between the provision for income taxes and the amount computed by applying the federal statutory income tax rate (35 percent) to income before taxes is explained below (in thousands):
 
Year Ended
 
June 30,
2015
 
June 30,
2014
 
June 30,
2013
Tax at federal statutory rate
$
(23,392
)
 
$
(18,592
)
 
$
3,973

State income tax, net of federal benefit
13

 
329

 
105

Change in valuation allowance
24,105

 
20,729

 
(3,687
)
Foreign earnings taxed at other than U.S. rates
(1,113
)
 
(346
)
 
498

Deferred compensation
2,298

 
348

 
845

Goodwill amortization
1,690

 
1,097

 

Other
1,206

 
624

 
(56
)
Provision for income taxes
$
4,807

 
$
4,189

 
$
1,678

Significant components of the Company’s deferred tax assets are as follows (in thousands):
 
June 30,
2015
 
June 30,
2014
 
June 30,
2013
Deferred tax assets:
 
 
 
 
 
Net operating loss carry-forwards
$
114,151

 
$
97,630

 
$
85,276

Tax credit carry-forwards
30,824

 
30,019

 
28,882

Depreciation

 
129

 

Intangible amortization
17,978

 
6,061

 

Deferred revenue (net)
7,811

 
10,540

 
9,710

Warrant amortization
1,355

 
2,723

 
3,991

Inventory write-downs
6,048

 
3,265

 
2,759

Other allowances and accruals
8,645

 
6,380

 
3,658

Stock based compensation
6,783

 
6,257

 
2,973

Other
5,902

 
10,772

 
5,741

Total deferred tax assets
199,497

 
173,776

 
142,990

Valuation allowance
(197,576
)
 
(172,475
)
 
(142,023
)
Total net deferred tax assets
1,921

 
1,301

 
967

Deferred tax liabilities:
 
 
 
 
 
Depreciation
(707
)
 

 
(388
)
Goodwill amortization
(2,787
)
 
(1,097
)
 

Brazilian foreign exchange gain

 
(2,670
)
 

Deferred tax liability on foreign withholdings
(194
)
 
(167
)
 
(134
)
Total deferred tax liabilities
(3,688
)
 
(3,934
)
 
(522
)
Net deferred tax assets (liabilities)
$
(1,767
)
 
$
(2,633
)
 
$
445

Recorded as:
 
 
 
 
 
Net current deferred tax assets
$
760

 
$
1,058

 
$
386

Net non-current deferred tax assets
452

 
230

 
294

Net current deferred tax liabilities

 
(2,657
)
 
(235
)
Net non-current deferred tax liabilities
(2,979
)
 
(1,264
)
 

Net deferred tax assets (liabilities)
$
(1,767
)
 
$
(2,633
)
 
$
445


 The Company's global valuation allowance increased by $25.1 million in the fiscal year ended June 30, 2015 and $30.5 million in the fiscal year ended June 30, 2014. 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 non-U.S. deferred tax assets in Australia, Brazil, Japan and Singapore. The valuation allowance is determined by assessing both negative and positive available evidence to assess whether it is more likely than not that the deferred tax assets will be recoverable. The Company's inconsistent earnings in recent periods, including a cumulative loss over the last three years, coupled with its difficulty in forecasting future revenue trends as well as the cyclical nature of the Company's business provides sufficient negative evidence to 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.
As of June 30, 2015, the Company had net operating loss carry-forwards for U.S. federal and state tax purposes of $330.6 million and $169.6 million, respectively, of which $38.6 million and $36.0 million, respectively, represent deductions from share-based compensation for which a benefit would be recorded in additional paid-in capital when realized. As of June 30, 2015, the Company also had foreign net operating loss carry-forwards in Ireland, Australia, Japan and Singapore of $53.1 million, $9.8 million, $0.3 million, and $1.4 million, respectively. As of June 30, 2015, the Company also had federal and state tax credit carry-forwards of $20.3 million and $16.2 million, respectively. These credit carry-forwards consist of research and development tax credits as well as foreign tax credits with a small portion representing Alternative Minimum Tax Credits. The U.S. federal net operating loss carry-forwards of $330.6 million will begin to expire in the fiscal year ending June 30, 2021 and state net operating losses of $169.6 million will begin to expire in the fiscal year ending June 30, 2016, if not utilized. The foreign net operating losses can generally be carried forward indefinitely. Federal research and development tax credits of $20.3 million will expire beginning in fiscal 2019, if not utilized and foreign tax credits of $7.0 million will expire beginning in fiscal 2021. 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 $15.3 million do not expire and can be carried forward indefinitely.
As of March 31, 2015, the Company performed an Internal Revenue Code section 382 analysis 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 tax attributes. It was determined that no ownership change had occurred during the fiscal year ended June 30, 2015, however, it is possible a subsequent ownership change could limit the utilization of the Company's tax attributes.
As of June 30, 2015, the Company intends to indefinitely reinvest the earnings of approximately $9.3 million of certain foreign corporations. The unrecognized deferred tax liability associated with these earnings is approximately $0.3 million.
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, Brazil, India, California, New Hampshire and North Carolina. The Company is not currently under examination by any federal, state or foreign tax authority with respect to income taxes. The Company recently settled an income tax examination of one of its subsidiaries with the Italian tax authorities. The tax reserves were adjusted appropriately to reflect this settlement.
In general, the Company's U.S. federal income tax returns are subject to examination by tax authorities for fiscal years 2001 forward due to net operating losses and the Company's state income tax returns are subject to examination for fiscal years 2000 forward due to net operating losses.
During the fiscal year ended June 30, 2014, the Company acquired the stock of Enterasys Networks, Inc. and as such they became a wholly owned subsidiary of Extreme Networks. With respect to this acquisition, the Company made an election under Internal Revenue Code section 338(h)(10) to treat the acquisition as an asset purchase from a tax perspective. Under this election the tax basis of all assets is effectively reset to that of fair market value and therefore the transaction did not result in the recording of an opening net deferred tax position as the Company's tax basis in the acquired assets equaled its book basis.
As of June 30, 2015, the Company had $11.4 million of unrecognized tax benefits. If fully recognized in the future, there would be no impact to the effective tax rate, and $11.4 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 decrease during the next twelve months.
A reconciliation of the beginning and ending amount of total unrecognized tax benefits is as follows (in thousands):
Balance at June 30, 2012
$
25,746

Decrease related to prior year tax positions
(14,966
)
Increase related to prior year tax positions
45

Increase related to current year tax positions
270

Lapse of statute of limitations
(197
)
Balance at June 30, 2013
$
10,898

Decrease related to prior year tax positions

Increase related to prior year tax positions
415

Increase related to current year tax positions
464

Lapse of statute of limitations
(177
)
Balance at June 30, 2014
$
11,600

Decrease related to prior year tax positions
(225
)
Increase related to prior year tax positions
288

Increase related to current year tax positions
254

Lapse of statute of limitations
(158
)
Settlements with tax authorities
(400
)
Balance at June 30, 2015
$
11,359


Estimated interest and penalties related to the underpayment of income taxes are classified as a component of tax expense in the consolidated statement of operations and totaled less than $0.1 million for each of the fiscal years 2015, 2014 and 2013. Accrued interest and penalties were less than $0.1 million for each of the fiscal years 2015, 2014 and 2013.