Income Taxes

3 Months Ended

Sep. 30, 2019

Income Tax Disclosure [Abstract]

Income Tax Disclosure [Text Block]

Income Taxes

Our income tax expense was $6,115 and $5,481 for the three months ended September 30, 2019 and 2018, respectively. The increase in tax expense is primarily attributable to increased pre-tax income for the three months ended September 30, 2019 as compared to the same prior year period. In addition, during the three months ended September 30, 2018, we recognized a decrease in deferred tax assets of $5,574 related to Notice 2018-68 issued by the United States Internal Revenue Service, which provided guidance regarding amendments to Section 162(m) of the Internal Revenue Code contained in the Tax Cuts and Jobs Act. Excluding the effect of discrete tax adjustments, our estimated annual effective tax rate is lower for fiscal 2020 as compared to fiscal 2019 primarily due to an expectation of a more favorable geographical mix of consolidated earnings. Our effective tax rate continues to be negatively impacted by losses in certain jurisdictions where we are unable to recognize a tax benefit in the current period.

On May 19, 2019, Swiss voters approved the Federal Act on Tax Reform and AHV Financing (TRAF), which will be effective as of January 1, 2020. The TRAF legislation provides a framework for the cantons of Switzerland to modify their existing tax laws. Changes in cantonal tax law will be applicable to taxpayers only at the conclusion of both the federal and cantonal legislative processes, despite the fact that the federal framework law sets forth required changes to cantonal law. On September 1, 2019, voters in the canton of Zurich approved the cantonal implementation of TRAF. However, the official results of the Zurich referendum had not been published as of September 30, 2019. As such, TRAF is not considered enacted as of September 30, 2019.

TRAF requires the abolishment of various favorable federal and cantonal tax regimes. TRAF also provides transitional relief measures, various tax benefits such as a patent box regime, and discretionary cantonal statutory tax rate reductions. While TRAF provides a variety of transitional measures and potential tax incentives to taxpayers, TRAF imposes a limitation whereby taxpayers can only eliminate up to 70% of their cantonal tax liability. We expect TRAF to be enacted in the quarter ending December 31, 2019, at which point we will remeasure our existing Swiss deferred tax assets and liabilities and establish new Swiss deferred tax assets related to transitional relief measures. We expect this will result in a material tax benefit in the quarter of enactment, but are unable to quantify the benefit at this time.

As of September 30, 2019, we had unrecognized tax benefits of $5,300, including accrued interest and penalties of $498. We recognize interest and, if applicable, penalties related to unrecognized tax benefits in the provision for income taxes. If recognized, the entire amount of unrecognized tax benefits would reduce our tax expense. It is reasonably possible that a reduction in unrecognized tax benefits may occur within the next twelve

months in the range of $400 to $800 related to the lapse of applicable statutes of limitations. We believe we have appropriately provided for all tax uncertainties.

We conduct business in a number of tax jurisdictions and, as such, are required to file income tax returns in multiple jurisdictions globally. The years 2016 through 2019 remain open for examination by the IRS and the years 2013 through 2019 remain open for examination in the various states and non-US tax jurisdictions in which we file tax returns. We believe that our income tax reserves are adequately maintained taking into consideration both the technical merits of our tax return positions and ongoing developments in our income tax audits. However, the final determination of our tax return positions, if audited, is uncertain, and there is a possibility that final resolution of these matters could have a material impact on our results of operations or cash flows.