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Income Taxes
3 Months Ended
Jan. 31, 2018
Income Tax Disclosure [Abstract]  
Income Taxes

13.       Income Taxes

 

The provision for income taxes was $48.6 million and $36.7 million, or 36.3 percent and 37.3 percent of pre-tax income, for the three months ended January 31, 2018 and 2017, respectively.

 

On December 22, 2017, the Tax Cuts and Jobs Act (the Tax Act) was signed into law in the U.S. Among other significant changes, the Tax Act reduced the statutory federal income tax rate for U.S. corporate taxpayers from a maximum of 35 percent to 21 percent and required the deemed repatriation of foreign earnings not previously subject to U.S. taxation. Because the lower federal income tax rate took effect two months into the Company's fiscal year, a blended federal tax rate of 23.3 percent applies to the Company for fiscal 2018.

 

The Company's income tax provision for the first quarter of fiscal 2018 includes a non-recurring charge of $24.7 million to reflect the estimated effect of the Tax Act. The non-recurring charge is considered to be a provisional estimate under the U.S. Securities and Exchange Commission Staff Accounting Bulletin 118 (SAB 118) and, based on current interpretation of the tax law changes, includes $21.7 million from the revaluation of the Company's deferred tax assets and liabilities, and $3.0 million for the deemed repatriation of foreign-sourced net earnings not previously subject to U.S. taxation. The increase in the Company's effective tax rate for the first quarter of fiscal 2018 resulting from this charge was partially offset by an income tax benefit of $11.9 million related to the exercise of stock options and vesting of restricted stock during the period, and $2.9 million related to the net income attributable to redeemable non-controlling interests and other beneficial interests, which is not taxable to the Company. The following table reconciles the statutory federal income tax rate to the Company's effective tax rate for the first quarter of fiscal 2018:

  Three Months Ended
  January 31, 2018
 Statutory U.S. federal income tax rate(1) 23.3%
 State income taxes for current year, net of federal income tax benefits 4.3%
 Net income attributable to non-controlling and other beneficial interests -1.8%
 Other items 0.9%
  Operating effective income tax rate 26.7%
 Non-recurring impact of U.S. tax reform 18.4%
 Net excess tax benefits from stock-based compensation plans(2) -8.8%
  Effective income tax rate 36.3%
    
 (1) Statutory U.S. federal income tax rate is a blend of 35 percent and 21 percent based on the number of days in the
 (1) Company's fiscal year before and after the January 1, 2018 effective date of the reduction in the federal corporate
 (1) income tax rate pursuant to the Tax Act.
 (2) This amount reflects the impact of Accounting Standard Update 2016-09, Improvements to Employee Share-Based
 (1) Payment Accounting, which was adopted in the first quarter of fiscal 2018. The Company anticipates that the adoption
 (1) of this guidance may cause fluctuations in the Company’s effective tax rate, particularly in the first quarter of each
 (1) fiscal year, when most of the Company’s annual stock-based awards vest.

The Company continues to carefully evaluate the impact of the Tax Act, certain provisions of which will not take effect for the Company until fiscal 2019, including, but not limited to, the global intangible low-taxed income, foreign-derived intangible income and base erosion anti-abuse tax provisions. Under the guidance issued by the Security and Exchange Commission SAB 118, no provisional estimate has been recorded for these items, as our accounting for these elements of the Tax Act is incomplete.

 

No valuation allowance has been recorded for deferred tax assets, reflecting management's belief that all deferred tax assets will be utilized.

 

As of January 31, 2018, the Company considers the undistributed earnings of certain foreign subsidiaries to be indefinitely reinvested in foreign operations; however, as a result of the Tax Act, an estimated tax of $3.0 was recorded in the quarter on these earnings. The calculation of this non-recurring charge is based on the Tax Act, guidance issued by the Internal Revenue Service and our interpretation of this information. The Company anticipates additional guidance will be issued by the Internal Revenue Service and continues to monitor interpretative developments. As a result, this estimated tax charge may change. In light of the changes contained in the Tax Act and as additional guidance becomes available, the Company may reconsider its repatriation policy.

 

The Company is generally no longer subject to income tax examinations by U.S. federal, state, local or non-U.S. taxing authorities for fiscal years prior to fiscal 2014.