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Income Taxes
3 Months Ended
Sep. 23, 2012
Income Taxes [Abstract]  
Income Taxes
13. Income Taxes

The Company's effective tax rate was a tax expense of 31.8 percent against a loss of $21.8 million and a tax expense of 22.2 percent against a profit of $28.2 million for the three months ended September 23, 2012 and September 25, 2011 respectively.  For the three months ended September 23, 2012, the Company's provision for taxes was not comparable to the United States ("U.S.") federal statutory rate of 35 percent.  The main components of the tax provision were a reduction in the U.K. statutory tax rates, reducing the value of the Company's net deferred tax assets in the U.K. by $3.2 million, a $2.2 million expense related to foreign income taxes, foreign withholding taxes, and no tax benefit from the ordinary loss in the U.S. due to the Company's valuation allowance position which were partially offset by benefitting a loss in a foreign jurisdiction.

During the three months ended September 23, 2012, the statutory tax rate in the U.K. was reduced from 25 percent to 24 percent, effective April 1, 2012, and further reduced to 23 percent effective April 1, 2013.  The Company reported a $3.2 million one-time expense due to the rate reduction on the deferred tax assets in the U.K. as a discrete item in the provision for income taxes.

For the three months ended September 25, 2011, the effective rate was lower than the U.S. federal statutory rate of 35 percent primarily due to the utilization of our deferred tax assets through a reduction of the beginning-of-the-year valuation allowance recorded in the U.K. and lower tax rates in certain foreign jurisdictions, and the impact on the tax provision due to the reduction of the U.K. statutory rate.
 






INTERNATIONAL RECTIFIER CORPORATION AND SUBSIDIARIES

NOTES TO UNAUDITED CONDENSED CONSOLIDATED FINANCIAL STATEMENTS (Continued)

13. Income Taxes (Continued)
 
      The Company evaluates its net deferred income tax assets quarterly to determine if valuation allowances are required. Based on the consideration of all available evidence using a "more-likely-than-not" standard, the Company determined that the valuation allowance established against its federal and California deferred tax assets in the U.S. should remain in place through fiscal year 2013.  These valuation allowances relate to beginning of the year balances of reserves that were established during fiscal year 2009.  During fiscal year 2012, the Company had released a remaining $28.6 million valuation allowance established against its deferred tax assets in the United Kingdom ("U.K.") as a result of cumulative pretax income generated by our U.K. subsidiary.

During fiscal years 2011 and 2012, the Company recorded deferred charges and valuation allowances related to certain intercompany transactions which reduced the respective deferred tax assets and associated valuation allowances in the U.K. and U.S.   Due to quarterly amortization of the deferred charge and valuation allowance for the three months ended September 23, 2012, these U.K. items were reduced by $0.7 million and $0.3 million, respectively, with the rest of them being an expense within the tax provision.  As a result of quarterly amortization of the deferred charge and valuation allowance for the three months ended September 23, 2012, these U.S. items were reduced by $0.5 million and $0.4 million, respectively, with the rest of them being an expense within the tax provision.

The Company operates in multiple foreign jurisdictions with lower statutory tax rates, and its operations in Singapore generally have the most significant impact on the Company's effective tax rate. During fiscal year 2011, the Company was granted certain incentives by the Singapore Economic Development Board.  As a result, the Company operates under a tax holiday in Singapore, effective from December 27, 2010 through December 26, 2020.  The tax holiday is conditioned upon the Company meeting certain employment and investment thresholds.

During the three months ended September 23, 2012, the reserve for uncertain tax positions increased by $0.8 million to $49.7 million.  This increase resulted primarily from changes in currency exchange rates related to prior year uncertain tax positions in certain foreign jurisdictions and additional reserves for state credits accrued during the three months ended September 23, 2012.  For fiscal year 2013, $0.1 million of increases to uncertain tax positions, if recognized, would affect the effective tax rate. The reserve is expected to decrease by $4.4 million during the next 12 months.

As of September 23, 2012, the Company had accrued $3.2 million of interest and penalties related to uncertain tax positions.  For the three months ended September 23, 2012, penalties and interest included in the reserves increased by $0.1 million.

While it is often difficult to predict the final outcome or the timing of the resolution of any particular uncertain tax position, the Company believes its reserve for income taxes represents the most probable outcome. The Company adjusts this reserve, including the portion related to interest, in light of changing facts and circumstances.

As of June 24, 2012, U.S. income taxes have not been provided on approximately $95.3 million of undistributed earnings of foreign subsidiaries since those earnings are considered to be invested indefinitely. Determination of the amount of unrecognized deferred tax liabilities for temporary differences related to investments in these non-U.S. subsidiaries that are essentially permanent in duration is not practicable.  The Company has not recorded a deferred tax liability on any potential gain as the earnings and profits of the subsidiary had been recognized as U.S. income in previous periods.

Pursuant to Sections 382 and 383 of the U.S. Internal Revenue Code, the utilization of net operating losses ("NOLs") and other tax attributes may be subject to substantial limitations if certain ownership changes occur during a three-year testing period (as defined). The Company does not believe an ownership change has occurred that would limit the Company's utilization of any NOL, credit carry forward or other tax attributes.