Income Taxes

6 Months Ended

Apr. 26, 2020

Income Tax Disclosure [Abstract]

Income Taxes

Income Taxes

Applied’s provision for income taxes and effective tax rate are affected by the geographical composition of pre-tax income which includes jurisdictions with differing tax rates, conditional reduced tax rates and other income tax incentives. It is also affected by events that are not consistent from period to period, such as changes in income tax laws and the resolution of prior years’ income tax filings.

On December 22, 2017, the U.S. government enacted the Tax Cuts and Jobs Act (Tax Act). The Tax Act includes provisions that impact Applied starting in fiscal 2019, including a provision designed to tax global intangible low-taxed income (GILTI). As a result, Applied realized a tax benefit of $50 million in the second quarter and $96 million in the first half of fiscal 2019. On June 14, 2019, the U.S. government released regulations that significantly affect how the GILTI provision of the Tax Act is interpreted. Accordingly, Applied reversed the tax benefit that had been realized in the first half of fiscal 2019.

On March 27, 2020, the U.S. government enacted the Coronavirus Aid, Relief, and Economic Security Act (CARES Act). The enactment of the CARES Act does not result in any material adjustments to Applied’s provision for income taxes.

Applied’s effective tax rates for the second quarter of fiscal 2020 and 2019 were 14.0 percent and 12.3 percent, respectively. The effective tax rate for the second quarter was higher than the same period in the prior fiscal year primarily due to an increase in tax expense in fiscal 2020 due to the tax benefit taken for GILTI in the second quarter of fiscal 2019 prior to the release of regulations on June 14, 2019 which resulted in the benefit no longer being realizable. This was partially offset by changes in uncertain tax positions.

Applied’s effective tax rates for the first half of fiscal 2020 and 2019 were 12.5 percent and 12.8 percent, respectively. The effective tax rate for the first half of fiscal 2020 was lower than the same period in the prior fiscal year primarily due to changes in uncertain tax positions and excess tax benefits from share-based compensation. This was partially offset by an increase in tax expense in fiscal 2020 due to the tax benefit taken for GILTI in the first half of fiscal 2019 prior to the release of regulations on June 14, 2019 which resulted in the benefit no longer being realizable.

During the next twelve months, it is reasonably possible that unrecognized tax benefits related to certain tax positions taken on previously filed tax returns could be recognized in the amount of approximately $29 million as a result of negotiations with tax authorities and lapses of statutes of limitation.