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Income Taxes - USD ($)
$ in Thousands
3 Months Ended 9 Months Ended
Mar. 27, 2021
Mar. 28, 2020
Mar. 27, 2021
Mar. 28, 2020
Income Tax Disclosure [Abstract]        
Effective Income Tax Rate Reconciliation, Percent 11.00% 11.30% 12.10% 12.00%
Income Tax Expense (Benefit) $ 27,199 $ 20,535 $ 78,600 $ 61,201
Significant Change in Unrecognized Tax Benefits is Reasonably Possible [Line Items]        
Document Period End Date     Mar. 27, 2021  
Effective Income Tax Rate Reconciliation, at Federal Statutory Income Tax Rate, Percent 21.00%      
Income tax provision $ 27,199 $ 20,535 $ 78,600 $ 61,201
Effective Income Tax Rate Reconciliation, at Federal Statutory Income Tax Rate, Percent 21.00%      
Income Taxes [Text Block]     INCOME TAXES
In the three and nine months ended March 27, 2021 the Company recorded an income tax provision of $27.2 million and $78.6 million, respectively, compared to $20.5 million and $61.2 million, for the three and nine months ended March 28, 2020, respectively. The Company’s effective tax rate for the three and nine months ended March 27, 2021 was 11.0% and 12.1%, respectively, compared to 11.3% and 12.0% for the three and nine months ended March 28, 2020, respectively.

The Company’s federal statutory tax rate is 21%. The Company’s effective tax rate for the three and nine months ended March 27, 2021 and March 28, 2020 was lower than the statutory rate primarily due to earnings of foreign subsidiaries, generated by the Company's international operations managed in Ireland, that were taxed at lower rates, partially offset by U.S. tax expense generated by Global Intangible Low-Taxed Income (“GILTI”). In addition, a $6.7 million discrete benefit for prior year Internal Revenue Code Section 199 (Domestic Production Activities) refund claims was recognized in the three and nine months ended March 27, 2021.
On June 18, 2019, the U.S. Treasury and Internal Revenue Service (“IRS”) released temporary regulations under Internal Revenue Code (“IRC”) Sections 245A and 954(c)(6) (the “Temporary Regulations”), which applied retroactively to intercompany dividends occurring after December 31, 2017. The Temporary Regulations limit the applicability of the foreign personal holding company income (“FPHCI”) look-through exception for certain intercompany dividends received by a controlled foreign corporation. Before application of the retroactive Temporary Regulations, the Company benefited in fiscal years 2018 and 2019 from the FPHCI look-through exception. On August 21, 2020, the U.S. Treasury and IRS released final regulations under IRC Sections 245A and 954(c)(6) (the “Final Regulations”), which generally apply to years ending on or after June 14, 2019. The relevant sections of the Final Regulations are virtually the same as the Temporary Regulations. The Temporary Regulations apply to fiscal year 2018 and the Final Regulations apply to fiscal year 2019 intercompany dividends. The Company does not have any intercompany dividends after fiscal year 2019 that are impacted by relevant sections of the Temporary Regulations or Final Regulations.

The Company previously analyzed the relevant Temporary Regulations and concluded that they were not validly issued, a conclusion which the Company has determined is not altered by issuance of the Final Regulations. The Company has also analyzed the relevant Final Regulations and concluded that they were not validly issued. Therefore, the Company has not accounted for the effects of the Temporary Regulations or Final Regulations in its results of operations for any fiscal period. The Company believes it has strong arguments in favor of its position and that it has met the more likely than not recognition threshold that its position will be sustained. The Company intends to vigorously defend its position, however, due to the uncertainty involved in challenging and litigating the validity of regulations, there can be no assurance that a court of law will rule in favor of the Company. An unfavorable resolution of this issue could have a material adverse impact on the Company's results of operations and financial condition.

The Company engages in continuous discussions and negotiations with tax authorities regarding tax matters in various jurisdictions. It is reasonably possible that the balance of gross unrecognized tax benefits, including accrued interest and penalties, could decrease up to $108.0 million within the next twelve months due to the completion of federal tax audits, including any administrative appeals. The $108.0 million primarily relates to matters involving federal taxation of international income and cross-border transactions.

The Company’s federal corporate income tax returns are audited on a recurring basis by the IRS. In fiscal year 2020, the IRS commenced an audit of the Company’s federal corporate income tax returns for fiscal years 2015 through 2017, which is ongoing. The Company expects that the IRS will commence an audit of the Company’s federal corporate income tax returns for fiscal years 2018 through 2020 in the summer of 2021.