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INCOME TAXES
3 Months Ended
Dec. 31, 2018
INCOME TAXES [Abstract]  
INCOME TAXES


15. INCOME TAXES

 The Company’s effective tax rate for the first quarter of fiscal 2019 was 20.4%, compared to 108.4% in the same quarter last year.  The significant decrease is primarily attributable to the changes introduced by the Tax Act enacted in December 2017.  The first quarter of fiscal 2019 was driven by unfavorable tax treatment of certain KMG acquisition-related costs, such as compensation deduction limitations, as well as non-deductibility of certain professional fees.  Additionally, we recorded incremental tax expense for the Global Intangible Low Taxed Income (“GILTI”) provision of the Tax Act which was effective for the first time during our fiscal 2019. Partially offsetting these adverse items, the Tax Act reduced the corporate income tax rate to 21.0% effective January 1, 2018, resulting in a change in our blended tax rate of 24.5% in fiscal 2018 to 21.0% beginning with our fiscal 2019.  In the quarter ended December 31, 2018, the Company completed its provisional estimates with regard to the Tax Act and the Transition Tax and Withholding Tax obligations are now determined to be complete.

  Deemed Repatriation Transition Tax:  Deemed repatriation tax (“Transition Tax”) is a tax on previously untaxed accumulated earnings and profits (E&P) of certain of our foreign subsidiaries.  To determine the amount of the Transition Tax, we determined, in addition to other factors, the amount of post-1986 E&P of the relevant subsidiaries, as well as the amount of non-U.S. withholding taxes on such earnings.  We were able to reasonably estimate the Transition Tax and recorded a provisional Transition Tax obligation of $11,340 in fiscal 2018.  On the basis of revised E&P computations that were completed during the reporting period, we recognized an additional measurement-period adjustment to the Transition Tax obligation with a corresponding benefit of $259 to income tax expense for the quarter ended December 31, 2018, resulting in a Transition Tax obligation of $11,081.  The Company made the decision to take the dividends received deduction (DRD) on its fiscal 2018 tax return and accordingly reflected a section 245A DRD with respect to the section 78 gross-up in its transition tax calculation. 
  Subsequent to the quarter end, Treasury released final regulations under Sec. 965.  The Company will complete its assessment of new regulatory guidance during the quarter ended March 31, 2019. 
In fiscal 2018, we also recorded a provisional estimate of $5,555 for non-U.S. withholding taxes to be incurred on actual and future distributions of foreign earnings as of December 31, 2017.  No changes have been made to this estimate for the quarter ended December 31, 2018.

Prior to fiscal 2018, the Company maintained an assertion to permanently reinvest the earnings of its non-U.S. subsidiaries outside of the U.S., with certain insignificant exceptions, and therefore, did not record U.S. deferred income taxes or foreign withholding taxes for these earnings.  In light of the Tax Act and the associated transition to a territorial tax system, the Company decided it will repatriate foreign earnings it expects to generate in current and future periods, and consequently recorded deferred tax liabilities associated with withholding taxes and state taxes on such planned distributions.

The Tax Act includes a provision designed to tax GILTI.  Under U.S. GAAP, we are allowed to make an accounting policy choice 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 “deferred method”).  The Company has elected the period cost method and has calculated its GILTI tax for fiscal 2019.