INCOME TAXES

The components of income from continuing operations upon which domestic and foreign income taxes have been provided are as follows:



(in 000s)
Year ended April 30,	2013		2012		2011
Domestic	$	664,966	$	547,535	$	590,024
Foreign	37,045		28,535		37,679
	$	702,011	$	576,070	$	627,703

The components of income tax expense (benefit) for continuing operations are as follows:



(in 000s)
Year ended April 30,	2013			2012		2011
Current:
Federal	$	219,411		$	126,773	$	171,337
State	43,116			21,285		40,433
Foreign	3,173			8,647		21,456
	265,700			156,705		233,226
Deferred:
Federal	(29,258		)	55,032		(1,762		)
State	(69		)	18,154		3,404
Foreign	480			211		288
	(28,847		)	73,397		1,930
Total income taxes for continuing operations	$	236,853		$	230,102	$	235,156

The reconciliation between the income tax provision and the amount computed by applying the statutory federal tax rate of 35% to income taxes of continuing operations is as follows:



Year ended April 30,	2013		2012		2011
U.S. statutory tax rate	35.0	%	35.0	%	35.0	%
Change in tax rate resulting from:
State income taxes, net of federal income tax benefit	4.0	%	4.2	%	4.4	%
Permanent differences	(0.1	)%	0.5	%	(0.6	)%
Uncertain tax positions	(4.1	)%	(0.6	)%	1.2	%
Net change in valuation allowance	(1.0	)%	0.2	%	(1.4	)%
Other	(0.1	)%	0.6	%	(1.1	)%
Effective tax rate	33.7	%	39.9	%	37.5	%

The net loss from discontinued operations for fiscal years 2013 and 2012 totaled $31.2 million and $80.0 million, respectively, compared to net income of $13.6 million in fiscal year 2011. These amounts are net of tax benefits of $19.7 million and $74.9 million in fiscal years 2013 and 2012, respectively, and tax expense of $13.8 million in fiscal year 2011. The effective tax rate for discontinued operations was 38.6%, 48.4% and 50.5% for fiscal years 2013, 2012 and 2011, respectively.

The significant components of deferred tax assets and liabilities are reflected in the following table:



(in 000s)
As of April 30,	2013			2012
Gross deferred tax assets:
Accrued expenses	$	15,842		$	21,533
Allowance for credit losses and related reserves	114,570			102,819
Capital loss carry-forward	45,826			—
Valuation allowance	(28,088		)	(33,672		)
Current	148,150			90,680
Deferred and stock-based compensation	20,758			23,590
Deferred revenue	30,225			26,181
Net operating loss carry-forward	20,070			18,202
State tax benefits related to federal unrecognized tax benefits	30,374			31,824
Capital loss carry-forward	2,379			85,778
Other	3,901			2,901
Valuation allowance	(26,525		)	(43,771		)
Noncurrent	81,182			144,705
	229,332			235,385
Gross deferred tax liabilities:
Prepaid expenses	(2,830		)	(3,641		)
Current	(2,830		)	(3,641		)
Property and equipment	(25,794		)	(19,454		)
Mortgage-related investment	(20,033		)	(63,115		)
Intangibles	(36,565		)	(33,935		)
Noncurrent	(82,392		)	(116,504		)
Net deferred tax assets	$	144,110		$	115,240

As of April 30, 2013 and 2012, we have deferred tax assets related to capital loss carry-forwards totaling $48.2 million and $85.8 million, respectively, which resulted primarily from the sale of our brokerage business in November 2008. Generally, for tax purposes, a capital loss can only be utilized to the extent we realize capital gains within five years of the end of the taxable year in which the capital loss was incurred. We have recorded a valuation allowance against our capital loss carry-forward of $39.0 million and $63.6 million as of April 30, 2013 and 2012, respectively. The total decrease in valuation allowance on deferred tax assets for the period ended April 30, 2013 was $22.8 million, of which only $5.5 million favorably impacted income tax expense. Substantially all of the valuation allowance decrease was offset by the shift of a deferred tax asset from the U.S. to a foreign jurisdiction as a result of an intercompany transaction. The effects of differing income tax laws and rates on the shift in deferred tax asset offset all but $5.5 million of the tax benefit from the decrease in the valuation allowance. As of April 30, 2013, the capital loss carry-forward totaled approximately $124 million, and will expire if not used to offset future capital gains before December 31, 2013.

Certain of our subsidiaries file stand-alone returns in various states and foreign jurisdictions, and others join in filing consolidated or combined returns in such jurisdictions. At April 30, 2013, we had net operating losses (NOLs) in various states and foreign jurisdictions. The amount of state NOLs vary by taxing jurisdiction. We recorded deferred tax assets of $20.1 million for the tax effects of such losses and a valuation allowance of $14.4 million for the portion of such losses that, more likely than not, will not be realized. If not used, the NOLs will expire in varying amounts during fiscal years 2014 through 2033.

We intend to indefinitely reinvest foreign earnings for virtually all of our foreign companies; therefore, no provision has been made for income taxes that might be payable upon remittance of such earnings. The amount of unrecognized deferred tax liability on unremitted foreign earnings is immaterial as of April 30, 2013.

Changes in unrecognized tax benefits for fiscal years 2013, 2012 and 2011 are as follows:



(in 000s)
Year ended April 30,	2013			2012			2011
Balance, beginning of the year	$	206,393		$	154,848		$	129,767
Additions based on tax positions related to prior years	11,867			26,523			28,262
Reductions based on tax positions related to prior years	(49,493		)	(3,858		)	(1,473		)
Additions based on tax positions related to the current year	2,314			42,735			3,417
Reductions related to settlements with tax authorities	(25,259		)	(8,742		)	(7,639		)
Expiration of statute of limitations	(702		)	(2,814		)	(315		)
Foreign currency translation	(278		)	(838		)	1,057
Other	1,549			(1,461		)	1,772
Balance, end of the year	$	146,391		$	206,393		$	154,848

Of the total ending gross unrecognized tax benefit balance as of April 30, 2013, 2012 and 2011, respectively, $95.3 million, $150.4 million and $117.6 million, respectively, if recognized, would impact our effective tax rate. The difference results from adjusting the gross balances for such items as federal, state and foreign deferred items, interest and deductible taxes. We believe it is reasonably possible that the balance of unrecognized tax benefits could decrease by approximately $38 million within the next twelve months due to settlements of audit issues and expiration of statutes of limitations.

Interest and penalties, if any, accrued on the unrecognized tax benefits are reflected in income tax expense. The amount of gross interest and penalties accrued on uncertain tax positions decreased $6.9 million and $5.5 million during fiscal years 2013 and 2012, respectively, and increased $4.4 million in fiscal year 2011. The total gross interest and penalties accrued as of April 30, 2013, 2012 and 2011 totaled $31.7 million, $38.6 million and $44.1 million, respectively.

We file a consolidated federal income tax return in the United States with the Internal Revenue Service (IRS) and file tax returns in various state and foreign jurisdictions. Tax returns are typically examined and settled upon completion of the exam, with tax controversies settled either at the exam level or through the appeal process.

In November 2012, we received written approval from the IRS Joint Committee on Taxation of the settlement of a majority of the issues related to the examination of our 1999 through 2007 tax returns. In fiscal year 2013, we recorded the impact of the settlement which reduced uncertain tax benefits by $59.0 million. Of this reduction, $33.3 million resulted in an income tax benefit.

Except for three issues for which we are pursuing refund claims for tax years 2002 through 2007, which will remain open until resolved, these years are closed. In addition, U.S. Federal consolidated tax returns for 2008 through 2010 are currently under examination. We anticipate the IRS exam of tax years 2008 through 2010 as well as the open refund claims for tax years 2002 through 2007 will be resolved within the next twelve months. Federal tax returns for calendar years 2011 through 2013 are open to examination.

The expected federal tax refund has been classified as current as of April 30, 2013. Of the $136.1 million expected federal refund, a $151.3 million asset is recorded in prepaid expenses and other current assets offset by a $15.2 million liability recorded in accrued income taxes.