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Note 7 - Income Taxes
12 Months Ended
Dec. 31, 2016
Notes to Financial Statements  
Income Tax Disclosure [Text Block]
7.
Income Taxes
 
Significant components of the provision (benefit) for income taxes for continuing operations are as follows
:
 
(in thousands)
 
2016
   
2015
   
2014
 
Current:
                       
U.S. Federal
  $
11
    $
5
    $
(307
)
U.S. State
   
8
     
28
     
40
 
Foreign
   
3,793
     
1,956
     
4,088
 
Total current
   
3,812
     
1,989
     
3,821
 
Deferred:
                       
U.S. Federal
   
91
     
89
     
112
 
U.S. State
   
47
     
49
     
(17
)
Foreign
   
(1,203
)    
84
     
737
 
Total deferred
   
(1,065
)    
222
     
832
 
    $
2,747
    $
2,211
    $
4,653
 
 
Income (loss) before income taxes from continuing operations consisted of the following
:
 
(in thousands)
 
2016
   
2015
   
2014
 
U.S.
  $
(13,420
)   $
(5,214
)   $
1,076
 
Foreign
   
19,427
     
13,217
     
18,357
 
Total
  $
6,007
    $
8,003
    $
19,433
 
 
Deferred income taxes reflect the net tax effects of temporary differences between the carrying amounts of assets and liabilities for financial reporting and tax purposes. Significant components of our deferred tax assets and liabilities were as follows:
 
 (in thousands)
 
2016
   
2015
 
Deferred tax assets:
               
Inventory, receivable and warranty reserves
  $
5,868
    $
8,207
 
Net operating loss carryforwards
   
11,681
     
7,605
 
Tax credit carryforwards
   
13,715
     
12,291
 
Accrued employee benefits
   
5,002
     
4,993
 
Deferred profit and gain on facility sale
   
5,412
     
6,084
 
Stock-based compensation
   
4,189
     
4,443
 
Acquisition basis differences
   
1,334
     
1,544
 
Other
   
103
     
265
 
Gross deferred tax assets
   
47,304
     
45,432
 
Less valuation allowance
   
(44,731
)    
(42,289
)
Total deferred tax assets
   
2,573
     
3,143
 
Deferred tax liabilities:
               
Depreciation and fixed asset related
   
53
     
227
 
Acquisition basis differences
   
7,423
     
8,904
 
Other
   
662
     
563
 
Total deferred tax liabilities
   
8,138
     
9,694
 
Net deferred tax liabilities
  $
(5,565
)   $
(6,551
)
 
Companies are required to assess whether a valuation allowance should be recorded against their deferred tax assets (“DTAs”) based on the consideration of all available evidence, using a “more likely than not” realization standard. The
four
sources of taxable income that must be considered in determining whether DTAs will be realized are,
(1)
future reversals of existing taxable temporary differences (i.e. offset of gross deferred tax assets against gross deferred tax liabilities);
(2)
taxable income in prior carryback years, if carryback is permitted under the tax law;
(3)
tax planning strategies and
(4)
future taxable income exclusive of reversing temporary differences and carryforwards.
 
In assessing whether a valuation allowance is required, significant weight is to be given to evidence that can be objectively verified. We have evaluated our DTAs each reporting period, including an assessment of our cumulative income or loss over the prior
three
-year period and future periods, to determine if a valuation allowance was required. A significant negative factor in our assessment was Cohu's
three
-year cumulative U.S. loss history at the end of various fiscal periods including
2016.
 
As a result of our cumulative,
three
-year U.S. GAAP pretax loss from continuing operations of approximately
$17.6
 million at the end of
2016,
and our U.S. loss in
2016,
we were unable to conclude at
December
31,
2016
that it was “more likely than not” that our U.S. DTAs would be realized. We will evaluate the realizability of our DTAs at the end of each quarterly reporting period in
2017
and should circumstances change it is possible the remaining valuation allowance, or a portion thereof, will be reversed in a future period.
 
Our valuation allowance on our DTAs at
December
31,
2016
and
December
26,
2015
was approximately
$44.7
 million and
$42.3
 million, respectively. The remaining gross DTAs for which a valuation allowance was not recorded are realizable through future reversals of existing taxable temporary differences.
 
As the realization of DTAs is determined by tax jurisdiction, the deferred tax liabilities recorded as part of the
2008
acquisition of Rasco, a German corporation, and the fiscal
2013
acquisition of Ismeca, a Swiss Corporation, were not a source of taxable income in assessing the realization of our DTAs in the U.S.
 
The reconciliation of income tax computed at the U.S. federal statutory tax rate to the provision for income taxes for continuing operations is as follows:
 
(in thousands)
 
2016
   
2015
   
2014
 
Tax provision at U.S. 35% statutory rate
  $
2,102
    $
2,801
    $
6,802
 
State income taxes, net of federal tax benefit
   
168
     
(152
)    
119
 
Settlements, adjustments and releases from statute expirations
   
(312
)    
(104
)    
(65
)
Federal tax credits
   
(183
)    
(221
)    
(244
)
Stock-based compensation on which no tax benefit provided
   
168
     
156
     
160
 
Change in valuation allowance
   
2,430
     
2,181
     
437
 
Non-deductible transaction costs
   
463
     
-
     
-
 
Foreign income taxed at different rates
   
(2,378
)    
(2,601
)    
(2,151
)
Other, net
   
289
     
151
     
(405
)
    $
2,747
    $
2,211
    $
4,653
 
 
State income taxes, net of federal benefit, have been reduced by research tax credits totaling approximately
$0.2
 million,
$0.4
 million and
$0.5
 million in
2016,
2015
and
2014,
respectively.
 
At
December
31,
2016,
we had federal, state and foreign net operating loss carryforwards of approximately
$31.0
 million,
$22.2
 million and
$0.2
 million, respectively, that expire in various tax years beginning in
2018
through
2036
or have no expiration date. We also have federal and state tax credit carryforwards at
December
31,
2016
of approximately
$8.2
 million and
$13.6
 million, respectively, certain of which expire in various tax years beginning in
2017
through
2036
or have no expiration date. The federal and state loss and credit carryforwards are subject to annual limitations under Sections
382
and
383
of the Internal Revenue Code and applicable state tax law.
 
U.S. income taxes have not been provided on approximately
$49
 million of accumulated undistributed earnings of certain foreign subsidiaries, as we currently intend to indefinitely reinvest these earnings in operations outside the U.S. We repatriated
$17.4
 million from our Singapore subsidiary in
2016
due to the reduction in business activity of that operation. Our intent is to continue to indefinitely reinvest the remaining funds in our foreign operations and we have no current plans that would require us to repatriate these funds to the U.S. It is not practicable to estimate the amount of tax that might be payable if some or all of such earnings were to be remitted.
 
We have certain tax holidays with respect to our operations in Malaysia and the Philippines. These holidays require compliance with certain conditions and expire at various dates through
2023.
The impact of these holidays was an increase in net income of approximately
$1.0
million or
$0.04
per share in
2016,
$0.8
 million, or
$0.03
per share, in
2015
and not significant in
2014.
 
A reconciliation of our gross unrecognized tax benefits, excluding accrued interest and penalties, is as follows:
 
(in thousands)
 
2016
   
2015
   
2014
 
Balance at beginning of year
  $
10,444
    $
10,841
    $
10,483
 
Gross additions for tax positions of current year
   
125
     
215
     
761
 
Gross additions for tax positions of prior years
   
58
     
248
     
365
 
Reductions due to lapse of the statute of limitations
   
(446
)    
(243
)    
(587
)
Foreign exchange rate impact
   
(106
)    
(617
)    
(181
)
Balance at end of year
  $
10,075
    $
10,444
    $
10,841
 
 
If the unrecognized tax benefits at
December
31,
2016
are ultimately recognized, approximately
$5.2
 million
($5.6
 million at
December
26,
2015)
would result in a reduction in our income tax expense and effective tax rate. It is reasonably possible that our gross unrecognized tax benefits as of
December
31,
2016
could decrease in
2017
by approximately
$0.8
 million as a result of the expiration of certain statutes of limitations.
 
We recognize interest and penalties related to unrecognized tax benefits in income tax expense. Cohu had approximately
$1.2
million and
$1.4
million accrued for the payment of interest and penalties at
December
31,
2016
and
December
26,
2015,
respectively. Interest expense, net of accrued interest reversed, was not significant in
2016,
$0.1
 million in
2015
and not significant in
2014.
 
Our U.S. federal and state income tax returns for years after
2012
and
2011,
respectively, remain open to examination, subject to the statute of limitations. Net operating loss and credit carryforwards arising prior to these years are also open to examination if and when utilized. The statute of limitations for the assessment and collection of income taxes related to our foreign tax returns varies by country. In the foreign countries where we have significant operations these time periods generally range from
four
to
ten
years after the year for which the tax return is due or the tax is assessed.