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INCOME TAXES
12 Months Ended
Sep. 30, 2015
INCOME TAXES  
INCOME TAXES

 

NOTE 4 INCOME TAXES

        The components of the provision for income taxes are as follows:

                                                                                                                                                                                    

 

 

Years Ended September 30,

 

 

 

2015

 

2014

 

2013

 

 

 

(in thousands)

 

Current:

 

 

 

 

 

 

 

 

 

 

Federal

 

$

84,229

 

$

323,386

 

$

315,820

 

Foreign

 

 

16,685

 

 

15,841

 

 

14,551

 

State

 

 

10,881

 

 

21,197

 

 

32,916

 

​  

​  

​  

​  

​  

​  

 

 

 

111,795

 

 

360,424

 

 

363,287

 

​  

​  

​  

​  

​  

​  

Deferred:

 

 

 

 

 

 

 

 

 

 

Federal

 

 

159,686

 

 

28,183

 

 

35,530

 

Foreign

 

 

(28,456

)

 

(3,265

)

 

(1,409

)

State

 

 

350

 

 

2,206

 

 

(4,564

)

​  

​  

​  

​  

​  

​  

 

 

 

131,580

 

 

27,124

 

 

29,557

 

​  

​  

​  

​  

​  

​  

Total provision

 

$

243,375

 

$

387,548

 

$

392,844

 

​  

​  

​  

​  

​  

​  

​  

​  

​  

​  

​  

​  

        The amounts of domestic and foreign income before income taxes are as follows:

                                                                                                                                                                                    

 

 

Years Ended September 30,

 

 

 

2015

 

2014

 

2013

 

 

 

(in thousands)

 

Domestic

 

$

676,146

 

$

1,061,006

 

$

1,071,435

 

Foreign

 

 

(10,499

)

 

35,308

 

 

42,862

 

​  

​  

​  

​  

​  

​  

 

 

$

665,647

 

$

1,096,314

 

$

1,114,297

 

​  

​  

​  

​  

​  

​  

​  

​  

​  

​  

​  

​  

        Deferred income taxes are provided for the temporary differences between the financial reporting basis and the tax basis of our assets and liabilities. Recoverability of any tax assets are evaluated and necessary allowances are provided. The carrying value of the net deferred tax assets is based on management's judgments using certain estimates and assumptions that we will be able to generate sufficient future taxable income in certain tax jurisdictions to realize the benefits of such assets. If these estimates and related assumptions change in the future, additional valuation allowances may be recorded against the deferred tax assets resulting in additional income tax expense in the future.

        The components of our net deferred tax liabilities are as follows:

                                                                                                                                                                                    

 

 

September 30,

 

 

 

2015

 

2014

 

 

 

(in thousands)

 

Deferred tax liabilities:

 

 

 

 

 

 

 

Property, plant and equipment

 

$

1,334,611 

 

$

1,187,774 

 

Available-for-sale securities

 

 

33,187 

 

 

83,787 

 

Other

 

 

3,928 

 

 

67 

 

​  

​  

​  

​  

Total deferred tax liabilities

 

 

1,371,726 

 

 

1,271,628 

 

​  

​  

​  

​  

Deferred tax assets:

 

 

 

 

 

 

 

Pension reserves

 

 

3,405 

 

 

1,370 

 

Self-insurance reserves

 

 

14,318 

 

 

10,311 

 

Net operating loss and foreign tax credit carryforwards

 

 

56,287 

 

 

48,285 

 

Financial accruals

 

 

63,560 

 

 

52,289 

 

Other

 

 

12,049 

 

 

8,332 

 

​  

​  

​  

​  

Total deferred tax assets

 

 

149,619 

 

 

120,587 

 

Valuation allowance

 

 

55,758 

 

 

47,699 

 

​  

​  

​  

​  

Net deferred tax assets

 

 

93,861 

 

 

72,888 

 

​  

​  

​  

​  

Net deferred tax liabilities

 

$

1,277,865 

 

$

1,198,740 

 

​  

​  

​  

​  

​  

​  

​  

​  

        The change in our net deferred tax assets and liabilities is impacted by foreign currency remeasurement.

        As of September 30, 2015, we had state and foreign net operating loss carryforwards for income tax purposes of $6.2 million and $20.7 million, respectively, and foreign tax credit carryforwards of approximately $59.4 million (of which $48.6 million is reflected as a deferred tax asset in our Consolidated Financial Statements prior to consideration of our valuation allowance) which will expire in fiscal 2016 through 2025. The valuation allowance is primarily attributable to state and foreign net operating loss carryforwards of $0.5 million and $6.6 million, respectively, and foreign tax credit carryforwards of $48.6 million which more likely than not will not be utilized.

        Effective income tax rates as compared to the U.S. Federal income tax rate are as follows:

                                                                                                                                                                                    

 

 

Years Ended
September 30,

 

 

 

2015

 

2014

 

2013

 

U.S. Federal income tax rate

 

 

35.0

%

 

35.0

%

 

35.0

%

Effect of foreign taxes

 

 

(2.1

)

 

1.2

 

 

1.1

 

State income taxes, net of federal tax benefit

 

 

0.8

 

 

1.4

 

 

1.5

 

U.S. domestic production activities

 

 

(1.2

)

 

(2.6

)

 

(2.1

)

Other impact of foreign operations

 

 

3.5

 

 

0.6

 

 

(0.5

)

Other

 

 

0.6

 

 

(0.2

)

 

0.3

 

​  

​  

​  

​  

​  

​  

Effective income tax rate

 

 

36.6

%

 

35.4

%

 

35.3

%

​  

​  

​  

​  

​  

​  

​  

​  

​  

​  

​  

​  

        Effective tax rates differ from the U.S. federal statutory rate of 35.0 percent primarily due to state and foreign income taxes and the tax benefit from the Internal Revenue Code Section 199 deduction for domestic production activities. The effective tax rate for the twelve months ended September 30, 2015 was also impacted by a December 2014 tax law change which resulted in a reduction of the fiscal 2014 Internal Revenue Code Section 199 deduction for domestic production activities. In addition, the effective tax rate for the twelve months ended September 30, 2015 was impacted by a reduction in the deferred state income tax rate.

        We recognize accrued interest related to unrecognized tax benefits in interest expense, and penalties in other expense in the Consolidated Statements of Income. As of September 30, 2015 and 2014, we had accrued interest and penalties of $11.1 million and $6.4 million, respectively.

        A reconciliation of the change in our gross unrecognized tax benefits for the fiscal year ended September 30, 2015 and 2014 is as follows:

                                                                                                                                                                                    

 

 

September 30,

 

 

 

2015

 

2014

 

 

 

(in thousands)

 

Unrecognized tax benefits at October 1,

 

$

10,747

 

$

8,129

 

Gross decreases—tax positions in prior periods

 

 

(706

)

 

(4

)

Gross increases—tax positions in prior periods

 

 

3,278

 

 

4,293

 

Gross decreases—current period effect of tax positions

 

 

(821

)

 

(836

)

Gross increases—current period effect of tax positions

 

 

 

 

4

 

Expiration of statute of limitations for assessments

 

 

(956

)

 

(533

)

Settlements

 

 

(331

)

 

(306

)

​  

​  

​  

​  

Unrecognized tax benefits at September 30,

 

$

11,211

 

$

10,747

 

​  

​  

​  

​  

​  

​  

​  

​  

        As of September 30, 2015 and September 30, 2014, our liability for unrecognized tax benefits includes $2.9 million, for each year, of unrecognized tax benefits related to discontinued operations that, if recognized, would not affect the effective tax rate. The remaining unrecognized tax benefits would affect the effective tax rate if recognized. The liabilities for unrecognized tax benefits and related interest and penalties are included in other noncurrent liabilities in our Consolidated Balance Sheets.

        For the next 12 months, we cannot predict with certainty whether we will achieve ultimate resolution of any uncertain tax position associated with our U.S. and international operations that could result in increases or decreases of our unrecognized tax benefits. However, we do not expect the increases or decreases to have a material effect on results of operations or financial position. We provided for uncertain tax positions of $6.7 million, including interest and penalties, during the twelve months ended September 30, 2015 related to the previous disclosure of a possible increase in the reserve for uncertain tax positions of approximately $8.4 million to $11.0 million due to international tax matters.

        We file a consolidated U.S. federal income tax return, as well as income tax returns in various states and foreign jurisdictions. The tax years that remain open to examination by U.S. federal and state jurisdictions include fiscal 2011 through 2014, with exception of certain state jurisdictions currently under audit. Audits in foreign jurisdictions are generally complete through fiscal 2002.

        On September 13, 2013, the IRS issued final regulations providing guidance on the treatment of amounts paid to acquire, produce or improve tangible property and proposed regulations providing guidance on the dispositions of such property. The implementation date for these regulations is tax years beginning on or after January 1, 2014. The estimated effect of the regulations have been included in the determination of our taxable income for the fiscal year end 2015 tax provision. The implementation of the regulations did not have a significant impact on the overall tax provision.