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INCOME TAXES
9 Months Ended
Aug. 02, 2020
INCOME TAXES  
INCOME TAXES

(9)  Income Taxes

The three-month effective tax rate increased from the third quarter of 2019 primarily due to unfavorable discrete adjustments related to finalizing estimated U.S. income tax on non-U.S. income from 2019, favorable discrete adjustments recorded in the third quarter of 2019, and a change in the 2020 forecasted geographic income.

The nine-month effective tax rate was also higher than 2019 due to the same items, partially offset by two discrete adjustments. In January 2020, the Company changed the corporate structure of two foreign holding subsidiaries to be indirect branches of Deere & Company. The change in tax status generated a capital loss that was carried back in the Company’s U.S. income tax return resulting in a $43 million benefit. In addition, a discrete benefit of $35 million was recognized in 2020 for the excess tax benefits related to vesting or exercise of share-based compensation awards.

The Company’s unrecognized tax benefits at August 2, 2020, November 3, 2019, and July 28, 2019 were $657 million, $553 million, and $630 million. The liability at August 2, 2020, November 3, 2019, and July 28, 2019 consisted of approximately $141 million, $153 million, and $274 million, respectively, which would affect the effective tax rate if the tax benefits were recognized. The remaining liability was related to tax positions for which there are offsetting tax receivables, or the uncertainty was only related to timing. The Company expects that any reasonably possible change in the amounts of unrecognized tax benefits in the next 12 months would not be significant.