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Provision for Income Taxes
6 Months Ended
Jan. 31, 2014
Provision for Income Taxes
12.

Provision for Income Taxes

The objectives of accounting for income taxes are to recognize the amount of taxes payable or refundable for the current period and deferred tax liabilities and assets for the future tax consequences of events that have been recognized in the Company’s financial statements or tax returns. Judgment is required in assessing the future tax consequences of events that have been recognized in our financial statements or tax returns. Fluctuations in the actual outcome of these tax consequences could materially impact our financial position or results of operations.

The Company recognizes liabilities for uncertain tax positions based on a two-step process. The first step is to evaluate the tax position for recognition by determining if the weight of available evidence indicates that it is more likely than not that the position will be sustained on audit, including resolution of related appeals or litigation processes, if any. The second step requires the Company to estimate and measure the tax benefit as the largest amount that is more than 50% likely to be realized upon ultimate settlement. It is inherently difficult and subjective to estimate such amounts, as the probability of various possible outcomes must be determined. These uncertain tax positions are re-evaluated on a quarterly basis. This evaluation is based on factors including, but not limited to, changes in facts or circumstances, changes in tax law, effectively settled issues under audit and new audit activity. Such a change in recognition or measurement would result in the recognition of a tax benefit or an additional charge to the tax provision.

It is the Company’s policy to recognize interest and penalties accrued relative to unrecognized tax benefits in income tax expense. For the six months ended January 31, 2014, the Company released $5,683 of gross uncertain tax positions and related interest and penalties recorded at July 31, 2013 related to the settlement of uncertain tax positions, which resulted in a net income tax benefit of $2,632. The Company accrued $586 in interest and penalties related to the remaining uncertain tax positions recorded at July 31, 2013. For the three months ended January 31, 2014, the Company released $4,041 of gross uncertain tax positions and related interest and penalties recorded at July 31, 2013 related to the settlement of uncertain tax positions, which resulted in a net income tax benefit of $1,624, and accrued $291 in interest and penalties.

The overall effective income tax rate for the three months ended January 31, 2014 was 28.0% compared with 22.2% for the three months ended January 31, 2013. The overall effective income tax rate for the six months ended January 31, 2014 was 31.6% compared with 30.4% for the six months ended January 31, 2013. The primary reason for the increase in the overall effective income tax rates for the three months and six months ended January 31, 2014 was the retroactive reinstatement of the Federal research and development credit and other credits that occurred during the fiscal 2013 periods. In addition, the effective income tax rates for both the fiscal 2013 and 2014 periods were favorably impacted from the settlement of certain uncertain tax benefits.

The Company anticipates a decrease of $3,660 in unrecognized tax benefits, and $895 in accrued interest and penalties related to these unrecognized tax benefits, within the next 12 months from expected settlements or payments of uncertain tax positions and lapses of the applicable statutes of limitations. In addition, the Company is currently in the process of pursuing a variety of settlement alternatives with taxing authorities. It is reasonably possible that some of these settlements could be finalized in the next 12 months. If these settlements are finalized within the next 12 months, the gross unrecognized tax benefits may decrease between $900 and $6,500 and related accrued interest and penalties may decrease between $400 and $3,800. It is reasonably possible that some of these settlements will result in cash payments by the Company. Actual results may differ materially from these estimates.

 

Generally, fiscal years 2010, 2011 and 2012 remain open for federal, state and foreign income tax purposes. The Company and its subsidiaries file a consolidated U.S. federal income tax return and multiple state income tax returns. The federal returns are subject to examination by taxing authorities for all years after fiscal 2009. The Company is currently under IRS audit for fiscal year 2011. The Company is also being audited by the state of California for tax years ended July 31, 2007 and July 31, 2008 and by the state of Indiana for tax years ended July 31, 2008, 2009 and 2010. The Company believes it has adequately reserved for its exposure to additional payments for uncertain tax positions related to its federal, California and Indiana income tax audits in its liability for unrecognized tax benefits.