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INCOME TAXES
3 Months Ended
Aug. 24, 2014
Income Tax Disclosure [Abstract]  
INCOME TAXES
INCOME TAXES
Our income tax expense from continuing operations for the first quarter of fiscal 2015 and 2014 was $42.5 million and $28.9 million, respectively. The effective tax rate (calculated as the ratio of income tax expense to pre-tax income from continuing operations, inclusive of equity method investment earnings) from continuing operations was approximately 28% and 18% for the first quarter of fiscal 2015 and 2014, respectively. The effective tax rate for the first quarter of fiscal 2015 reflects the resolution of uncertain tax positions. The low effective tax rate for the first quarter of fiscal 2014 was primarily due to a change in estimate related to the tax methods used for certain international sales, a change in deferred state tax rates relating to the integration of Ralcorp activity for tax purposes, and the settlement of a tax issue in Mexico that was previously reserved.
The amount of gross unrecognized tax benefits for uncertain tax positions, including positions impacting only the timing of tax benefits, was $75.1 million as of August 24, 2014 and $84.9 million as of May 25, 2014. Included in the balance was $8.2 million as of both August 24, 2014 and May 25, 2014, for tax positions for which the ultimate deductibility is highly certain but for which there is uncertainty about the timing of such deductibility. Because of the impact of deferred tax accounting, the disallowance of the shorter deductibility period would not affect the annual effective tax rate but would accelerate the payment of cash to the taxing authority to an earlier period. Any associated interest and penalties imposed would affect the tax rate. The gross unrecognized tax benefits excluded related liabilities for gross interest and penalties of $26.9 million and $29.6 million as of August 24, 2014 and May 25, 2014, respectively.
The net amount of unrecognized tax benefits at August 24, 2014 and May 25, 2014 that, if recognized, would impact the Company's effective tax rate was $44.1 million and $50.8 million, respectively. Recognition of these tax benefits would have a favorable impact on the Company's effective tax rate.
We estimate that it is reasonably possible that the amount of gross unrecognized tax benefits will decrease by up to $19.7 million over the next twelve months due to various federal, state, and foreign audit settlements and the expiration of statutes of limitations.