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Income Taxes
6 Months Ended
Dec. 27, 2013
Income Tax Disclosure [Abstract]  
Income Taxes
Income Taxes
 
The Company recorded an income tax provision of $14 million and $27 million in the three and six months ended December 27, 2013, respectively. The income tax provision recorded for the three and six months ended December 27, 2013 included approximately $4 million and $6 million, respectively, of net discrete tax expense primarily related to increases in income tax reserves recorded for non-U.S. income positions taken in prior fiscal years offset by the tax benefits from the reversal of a portion of the U.S. valuation allowance recorded in prior periods and tax benefits associated with the release of tax reserves associated with the expiration of certain statutes of limitation.  
 
The Company's income tax provision recorded for the three and six months ended December 27, 2013 differed from the provision for income taxes that would be derived by applying the Irish statutory rate of 25% to income before income taxes, primarily due to the net effect of (i) tax benefits related to non-U.S. earnings generated in jurisdictions that are subject to tax holidays or tax incentive programs and are considered indefinitely reinvested outside of Ireland and (ii) a decrease in valuation allowance for certain U.S. deferred tax assets.

The IRS and Treasury Department on September 13, 2013, released final regulations under Sections 162(a) and 263(a) on the deduction and capitalization of expenditures related to tangible personal property (the final repair regulations). The entirety of the final repair regulations apply to the Company’s first quarter of fiscal year 2015. Application of these regulations is not expected to have a material impact on the Company’s consolidated financial statements.

During the six months ended December 27, 2013, the Company's unrecognized tax benefits excluding interest and penalties increased by $16 million to $173 million. The unrecognized tax benefits that, if recognized, would impact the effective tax rate was $173 million at December 27, 2013, subject to certain future valuation allowance reversals. During the 12 months beginning December 28, 2013, the Company expects to reduce its unrecognized tax benefits by approximately zero to $30 million primarily as a result of the completion of various audit cycles and the expiration of certain statutes of limitation.

The income tax provision of $7 million recorded for the three months ended December 28, 2012 included approximately $6 million of discrete tax benefits primarily from the release of tax reserves associated with the expiration of certain statutes of limitation. The income tax provision of $25 million recorded for the six months ended December 28, 2012 included approximately $1 million of net discrete tax expense primarily associated with the reversal of prior period tax benefits offset by the release of tax reserves associated with the expiration of certain statutes of limitation.

The Company's income tax provision recorded for the three and six months ended December 28, 2012 differed from the provision for income taxes that would be derived by applying the Irish statutory rate of 25% to income before income taxes, primarily due to the net effect of (i) tax benefits related to non-U.S. earnings generated in jurisdictions that are subject to tax holidays or tax incentive programs and are considered indefinitely reinvested outside of Ireland and (ii) a decrease in valuation allowance for certain U.S. deferred tax assets.