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Income Taxes
6 Months Ended
Oct. 31, 2013
Income Tax Disclosure [Abstract]  
Income Taxes
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 at either the exam level or through an appeal process.
In August 2013, we received written approval from the IRS Joint Committee on Taxation of the settlement of all issues related to the examination of our 2008 through 2010 federal income tax returns. The resulting reduction in uncertain tax benefits had an immaterial impact on our tax expense during the quarter. The Company’s U.S. federal consolidated tax returns for 2011 and 2012 are currently under examination.
We had gross unrecognized tax benefits of $129.8 million, $207.4 million and $146.4 million as of October 31, 2013 and 2012 and April 30, 2013, respectively. The gross unrecognized tax benefits decreased $16.6 million and increased $1.0 million during the six months ended October 31, 2013 and 2012, respectively. The decrease in unrecognized tax benefits during the second quarter ending October 31, 2013 is primarily due to the settlement with the IRS of tax years 2008-2010. We believe it is reasonably possible that the balance of unrecognized tax benefits could decrease by approximately $23 million before October 31, 2014. The anticipated decrease is due to the expiration of statutes of limitations and anticipated settlements of state audit issues. This amount is included in accrued income taxes in our consolidated balance sheet. The remaining liability for uncertain tax positions is classified as long-term and is included in other noncurrent liabilities in the consolidated balance sheet.
Consistent with prior years, our operating loss for the six months ended October 31, 2013 is expected to be offset by income in later periods of our fiscal year due to the established pattern of seasonality in our primary business operations. As such, management has determined that it is more-likely-than-not that realization of tax benefits recorded in our financial statements will occur in our fiscal year. The amount of tax benefit recorded reflects management’s estimate of the annual effective tax rate applied to the year-to-date loss from continuing operations. Certain discrete tax adjustments are also reflected in income tax expense for the periods presented.
Excluding discrete items, management’s estimate of the annualized effective tax rate for the six months ended October 31, 2013 and 2012 was 38.7% and 38.9%, respectively. Our effective tax rate for continuing operations, including the effects of discrete income tax items, was 40.6% and 37.6% for the six months ended October 31, 2013 and 2012, respectively. Due to losses in both periods, a discrete tax benefit in either period increases the tax rate while an item of discrete tax expense decreases the tax rate. During the six months ended October 31, 2013, a net discrete tax benefit of $6.9 million was recorded compared to a net discrete tax expense of $4.2 million in the same period of the prior year.