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INCOME TAXES
3 Months Ended
Aug. 29, 2021
Income Tax Disclosure [Abstract]  
INCOME TAXES

10. INCOME TAXES

In the first quarter of fiscal 2022 and 2021, we recognized income tax expense of $69.7 million and $86.7 million, respectively. The effective tax rate (calculated as the ratio of income tax expense to pre-tax income, inclusive of equity method investment earnings) was 22.8% and 20.8% for the first quarter of fiscal 2022 and 2021, respectively.

The effective tax rate in the first quarter of fiscal 2022 reflected a benefit of $3.6 million from the settlement of tax issues that were previously reserved.

The effective tax rate for the first quarter of fiscal 2021 reflected a benefit of $7.6 million resulting from the regulations issued by the U.S. Treasury and Internal Revenue Service on certain provisions of the 2017 Tax Cuts and Jobs Act.

The amount of gross unrecognized tax benefits for uncertain tax positions was $26.0 million as of August 29, 2021 and $33.0 million as of May 30, 2021. Included in both amounts was $0.8 million for tax positions for which the ultimate deductibility is highly certain but for which there is uncertainty about the timing of such deductibility. The gross unrecognized tax benefits excluded related liabilities for gross interest and penalties of $7.8 million and $8.8 million as of August 29, 2021 and May 30, 2021, respectively.

The net amount of unrecognized tax benefits at August 29, 2021 and May 30, 2021 that, if recognized, would impact the Company's effective tax rate was $21.3 million and $28.2 million, respectively.

We estimate that it is reasonably possible that the amount of gross unrecognized tax benefits will decrease by up to $7.9 million over the next twelve months due to various state audit settlements and the expiration of statutes of limitations.

In fiscal 2021, we completed a restructuring of our ownership interest in the Ardent Mills joint venture, a milling business, that utilized a portion of our capital loss carryforward prior to its expiration. Also in fiscal 2021, we completed several other transactions related to retained assets in conjunction with the divestitures of the Peter Pan® peanut butter and Egg Beaters® businesses that we believe will utilize a portion of the remaining capital loss carryforward. These transactions are subject to certain elections and are currently under review by the Internal Revenue Service. We believe they may result in increases to the tax basis in those assets and if successful would result in tax benefits being realized in future periods.

We have not provided any deferred taxes on undistributed earnings of our foreign subsidiaries. Deferred taxes will be provided for earnings of non-U.S. affiliates and associated companies when we determine that such earnings are no longer indefinitely reinvested and will result in a tax liability upon distribution.