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Income Taxes
6 Months Ended
Oct. 31, 2018
Income Tax Disclosure [Abstract]  
Income Taxes
NOTE 7: INCOME TAXES
We file a consolidated federal income tax return in the U.S. with the IRS and file tax returns in various state, local, and foreign jurisdictions. Tax returns are typically examined and either settled upon completion of the examination or through the appeals process. The Company's U.S. federal income tax return for 2016 is currently under examination. Our U.S. federal income tax return for 2015 remains open for examination. Our U.S. federal income tax returns for 2014 and all prior periods are closed. With respect to state and local jurisdictions and countries outside of the U.S., we are typically subject to examination for three to six years after the income tax returns have been filed. Although the outcome of tax audits are always uncertain, we believe that adequate amounts of tax, interest, and penalties have been provided for in the accompanying consolidated financial statements for any adjustments that might be incurred due to federal, state, local or foreign audits.
On December 22, 2017, the U.S. government enacted the Tax Legislation, which made broad and complex changes to the U.S. tax code that impacted our financial statements, the most significant being a reduction in the U.S. federal corporate income tax rate from 35% to 21% and the imposition of a one-time transition tax on certain earnings of foreign subsidiaries. In addition, the Securities and Exchange Commission (SEC) staff issued Staff Accounting Bulletin 118 (SAB 118), which provides guidance on accounting for the tax effects of the Tax Legislation. SAB 118 provides a measurement period that should not extend beyond one year from the Tax Legislation’s enactment date for companies to complete their analysis and apply the provisions of the Tax Legislation to their financial statements. To the extent a company’s accounting for certain income tax effects of the Tax Legislation is incomplete but the company is able to determine a reasonable estimate, it must record a provisional estimate in the financial statements. If a company cannot determine a provisional estimate to be included in the financial statements, it should continue to apply the provisions of the tax laws that were in effect immediately before the enactment of the Tax Legislation.
In the second quarter of fiscal year 2019, we filed our calendar year 2017 U.S. federal income tax return and continued our assessment of the corporate income tax impacts of the Tax Legislation. During the six months ended October 31, 2018, the Company recognized immaterial adjustments to the provisional amounts recorded as of April 30, 2018 and included these adjustments as a component of income tax expense from continuing operations. Our financial statements reflect reasonable provisional estimates of the effects of the Tax Legislation in computing our deferred taxes, the one-time transition tax, the impact of global intangible low taxed income (GILTI), unrecognized tax benefits, and the indirect impacts of the Tax Legislation on state and local taxes.
We are in the process of finalizing our assessment of the impact of the Tax Legislation and our provisional estimates may change as a result of additional analysis of the underlying calculations, or additional regulatory guidance that clarifies the interpretations of the Tax Legislation. As we interpret additional guidance issued by the IRS, U.S. Department of the Treasury, or other standard-setting organizations, and consult with outside advisors, we may adjust these provisional amounts in accordance with SAB 118. The final adjustments will be recorded in the third quarter of fiscal year 2019 and may differ from the estimates provided and could have a material impact on our financial statements. Additionally, due to the complexity of the Tax Legislation as it relates to GILTI, we are continuing to evaluate how the income tax provision will be accounted for under GAAP, which permits companies to make an accounting policy election to either (i) account for GILTI as a component of tax expense in the period in which the company is subject to the rules, or (ii) account for GILTI in the company's measurement of deferred taxes. Currently, we have not elected a method.
Consistent with prior years, our pretax loss for the six months ended October 31, 2018 is expected to be offset by income in the fourth quarter due to the established pattern of seasonality in our primary business operations. As such, management has determined that it is at least more-likely-than-not that realization of tax benefits recorded in our financial statements will occur within our fiscal year. The amount of tax benefit recorded for the six months ended October 31, 2018 reflects management’s estimate of the annual effective tax rate applied to the year-to-date loss from continuing operations adjusted for the tax impact of items discrete to the quarter.
Our effective tax rate from continuing operations, including the effects of discrete income tax items, was 25.8% and 37.5% for the six months ended October 31, 2018 and 2017, respectively. The reduced effective tax rate results primarily from the decrease in the U.S. federal corporate income tax rate from 35% to 21%, effective January 1, 2018.
We had gross unrecognized tax benefits of $189.6 million, $132.9 million and $186.1 million as of October 31, 2018 and 2017 and April 30, 2018, respectively. The gross unrecognized tax benefits increased $3.5 million and decreased $17.0 million during the six months ended October 31, 2018 and 2017, respectively. We believe it is reasonably possible that the balance of unrecognized tax benefits could decrease by approximately $31.1 million within the next twelve months. The anticipated decrease is due to the expiration of statutes of limitations, and anticipated closure of various tax matters currently under examination, and settlements with tax authorities. For such matters where a change in the balance of unrecognized tax benefits is not reasonably possible, no estimate has been included.
The increase in noncurrent deferred tax assets and income taxes receivable of $96.9 million from April 30, 2018 is primarily due to the adoption of ASU 2016-16. See note 1 for additional information.