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Income Taxes
12 Months Ended
Apr. 30, 2014
Income Tax Disclosure [Abstract]  
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,
 
2014

 
2013

 
2012

Domestic
 
$
754,036

 
$
664,966

 
$
547,535

Foreign
 
13,080

 
37,045

 
28,535

 
 
$
767,116

 
$
702,011

 
$
576,070

 
 
 
 
 
 
 

The components of income tax expense (benefit) for continuing operations are as follows:
(in 000s)
 
Year ended April 30,
 
2014

 
2013

 
2012

Current:
 
 
 
 
 
 
Federal
 
$
195,277

 
$
219,411

 
$
126,773

State
 
33,274

 
43,116

 
21,285

Foreign
 
6,749

 
3,173

 
8,647

 
 
235,300

 
265,700

 
156,705

Deferred:
 
 
 
 
 
 
Federal
 
28,624

 
(29,258
)
 
55,032

State
 
5,475

 
(69
)
 
18,154

Foreign
 
(2,380
)
 
480

 
211

 
 
31,719

 
(28,847
)
 
73,397

Total income taxes for continuing operations
 
$
267,019

 
$
236,853

 
$
230,102

 
 
 
 
 
 
 

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,
 
2014

 
2013

 
2012

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
 
3.8
 %
 
4.0
 %
 
4.2
 %
Permanent differences
 
0.1
 %
 
(0.1
)%
 
0.5
 %
Uncertain tax positions
 
(5.6
)%
 
(4.1
)%
 
(0.6
)%
Change in valuation allowance
 
1.5
 %
 
(1.0
)%
 
0.2
 %
Other
 
 %
 
(0.1
)%
 
0.6
 %
Effective tax rate
 
34.8
 %
 
33.7
 %
 
39.9
 %
 
 
 
 
 
 
 

The reduction in the tax rate for fiscal year 2014 related to uncertain tax positions reflects changes to tax reserves related to settlements and new information regarding prior year tax positions.
The net loss from discontinued operations for fiscal years 2014, 2013 and 2012 totaled $24.9 million, $31.2 million and $80.0 million, respectively, and was net of tax benefits of $15.4 million, $19.7 million and $74.9 million, respectively.
The significant components of deferred tax assets and liabilities are reflected in the following table:
(in 000s)
 
As of April 30,
 
2014

 
2013

Gross deferred tax assets:
 
 
 
 
Accrued expenses
 
$
34,052

 
$
15,842

Allowance for credit losses and related reserves
 
115,145

 
114,570

Capital loss carry-forward
 

 
45,826

Valuation allowance
 
(10,837
)
 
(28,088
)
Current
 
138,360

 
148,150

 
 
 
 
 
Deferred and stock-based compensation
 
21,348

 
20,758

Deferred revenue
 
8,090

 
30,225

Net operating loss carry-forward
 
21,434

 
20,070

Federal tax benefits related to state unrecognized tax benefits
 
28,601

 
30,374

Capital loss carry-forward
 

 
2,379

Other
 
9,861

 
3,901

Valuation allowance
 
(8,339
)
 
(26,525
)
Noncurrent
 
80,995

 
81,182

 
 
 
 
 
 
 
219,355

 
229,332

Gross deferred tax liabilities:
 
 
 
 
Prepaid expenses
 
(3,033
)
 
(2,830
)
Current
 
(3,033
)
 
(2,830
)
 
 
 
 
 
Property and equipment
 
(28,610
)
 
(25,794
)
Mortgage-related investment
 
(15,441
)
 
(20,033
)
Intangibles
 
(59,881
)
 
(36,565
)
Noncurrent
 
(103,932
)
 
(82,392
)
 
 
 
 
 
Net deferred tax assets
 
$
112,390

 
$
144,110

 
 
 
 
 

Our valuation allowance on deferred tax assets decreased $35.4 million from $54.6 million at April 30, 2013, to $19.2 million at April 30, 2014. The decrease in the valuation allowance related almost entirely to deferred tax assets for capital loss carry-forwards totaling $45.8 million at April 30, 2013, which were fully realized during the fiscal year ended April 30, 2014.
During 2014 we determined we would not implement a previously identified qualified tax-planning strategy for which we had expected to implement and realized a tax benefit in a prior period. Our decision to abandon this tax planning strategy resulted in an increase to our valuation allowance and income tax expense of $9.2 million. Additionally, we made an election on our U.S. income tax return to treat a transfer of ownership of an international subsidiary to a consolidated affiliate in a manner which resulted in recognizing a capital gain for income tax purposes. No gain or loss was recorded for financial reporting purposes upon this transfer of ownership. As a result of this transaction we reduced deferred tax assets for capital loss carry-forwards and corresponding valuation allowances to zero, with no impact to income tax expense or our effective tax rate.
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. As of April 30, 2014, we had net operating losses (NOLs) in various states and foreign jurisdictions. The amount of state NOLs vary by taxing jurisdiction. We maintain a deferred tax asset of $21.4 million for the tax effects of such losses and a valuation allowance of $15.1 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 2015 through 2033.
We intend to indefinitely reinvest the foreign earnings of our foreign subsidiaries; therefore, no provision has been made for income taxes that might be payable upon remittance of such earnings. The amount of unrecognized tax liability on these foreign earnings, net of expected foreign tax credits, is less than $10 million as of April 30, 2014.
Changes in unrecognized tax benefits for fiscal years 2014, 2013 and 2012 are as follows:
(in 000s)
 
Year ended April 30,
 
2014

 
2013

 
2012

Balance, beginning of the year
 
$
146,391

 
$
206,393

 
$
154,848

Additions based on tax positions related to prior years
 
9,743

 
11,867

 
26,523

Reductions based on tax positions related to prior years
 
(25,403
)
 
(49,493
)
 
(3,858
)
Additions based on tax positions related to the current year
 
7,399

 
2,314

 
42,735

Reductions related to settlements with tax authorities
 
(23,993
)
 
(25,259
)
 
(8,742
)
Expiration of statute of limitations
 
(11,853
)
 
(702
)
 
(2,814
)
Foreign currency translation
 

 
(278
)
 
(838
)
Other
 
9,207

 
1,549

 
(1,461
)
Balance, end of the year
 
$
111,491

 
$
146,391

 
$
206,393

 
 
 
 
 
 
 

The total gross unrecognized tax benefit ending balance as of April 30, 2014, 2013 and 2012, includes $73.7 million, $95.3 million and $150.4 million, respectively, which 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 $5 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 total gross interest and penalties accrued as of April 30, 2014, 2013 and 2012 totaled $24.6 million, $31.7 million and $38.6 million, respectively.
We file a consolidated federal income tax return in the U.S. 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 examination, with tax controversies settled either at the examination level or through the appeals 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 tax returns. We recorded the impact of the settlement during fiscal year 2014, which reduced uncertain tax benefits by $17.3 million. In addition, we settled with certain state tax authorities during fiscal year 2014, reducing uncertain tax benefits by $6.7 million. These settlements did not have a significant impact on our effective tax rate in fiscal year 2014. These settlements and the receipt of the related tax refunds resulted in a decline in prepaid expenses and other current assets, as we recorded a $151.3 million current asset for the anticipated refund as of April 30, 2013.
Federal consolidated tax returns for calendar years 2011 and 2012 are currently under examination. Our federal consolidated income tax returns for calendar years 2013 and 2014 have not yet been filed but, once filed, will be subject to potential examination.