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Income Taxes
12 Months Ended
Jun. 25, 2011
Income Tax Disclosure [Abstract]  
Income Taxes [Text Block]
INCOME TAXES


The provision for income taxes consisted of the following:


 
For the Year Ended
 
June 25, 2011
 
June 26, 2010
 
June 27, 2009
 
(in thousands)
Federal
 


 
 


 
 


     Current
$
44,579


 
$
151,786


 
$
30,237


     Deferred
118,351


 
12,340


 
(7,447
)
State
 
 
 
 
 
     Current
781


 
4,092


 
(2,056
)
     Deferred
4,204


 
(1,464
)
 
(681
)
Foreign 
 
 
 
 
 
     Current
2,810


 
14,345


 
2,995


     Deferred                                                                                                                       
1,937


 
(6,175
)
 
1,116


 
$
172,662


 
$
174,924


 
$
24,164






Pretax income (loss) from the Company's foreign subsidiaries was approximately $285.0 million, $(95.5) million and $(63.3) million for fiscal years ended June 25, 2011, June 26, 2010 and June 27, 2009, respectively.


The Company has tax holidays with respect to certain operations in Thailand and the Philippines. The Thailand and Philippines tax holidays will expire at various dates between the fiscal years 2012 and 2019. The impact of the tax holidays on net income was not material for fiscal years 2011, 2010, and 2009.


As of June 25, 2011, the Company's foreign subsidiaries have accumulated undistributed earnings of approximately $123.8 million that are intended to be indefinitely reinvested outside the U.S. and, accordingly, no provision for U.S. federal and state tax has been made for the distribution of these earnings. At June 25, 2011 the amount of the unrecognized deferred tax liability on the indefinitely reinvested earnings was $39.9 million.


The provision for income taxes differs from the amount computed by applying the statutory rate as follows:


 
For the Year Ended
 
June 25, 2011


 
June 26, 2010


 
June 27, 2009


 
 
Federal statutory rate
35.0
 %
 
35.0
 %
 
35.0
 %
State tax, net of federal benefit
0.7


 
0.4


 
(10.8
)
General business credits
(1.5
)
 
(1.2
)
 
(25.6
)
Domestic production deduction benefit
(0.1
)
 
(2.1
)
 
(16.1
)
Foreign earnings and losses taxed or benefitted at different rates
(4.6
)
 
21.0


 
76.5


Stock-based compensation
1.3


 
3.0


 
8.4


Acquired in process R&D


 


 
3.9


Executive compensation
0.1


 
0.1


 
(11.2
)
Release of unrecognized tax benefits
(4.1
)
 


 


Interest accrual for unrecognized tax benefits
(1.6
)
 
0.9


 
9.9


Other
0.9


 
1.2


 
(0.2
)
 
 
 
 
 
 
Income tax rate
26.1
 %
 
58.3
 %
 
69.8
 %




Deferred income taxes reflect the net tax effects of temporary differences between the carrying amounts of assets and liabilities for financial reporting purposes and the amounts used for income tax purposes. The components of the Company's deferred tax assets and liabilities are as follows:


 
For the Year Ended
 
June 25, 2011
 
June 26, 2010
 
(in thousands)
Deferred tax assets:
 


 
 


     Inventory valuation and reserves
$
11,768


 
$
66,087


     Distributor related accruals and sales return and allowance accruals
21,334


 
14,168


     Deferred revenue
2,233


 
3,187


     Accrued compensation
56,467


 
47,500


     Stock-based compensation
73,295


 
84,225


     Net operating loss carryovers
20,827


 
31,450


     Tax credit carryovers
43,285


 
46,025


     Other reserves and accruals not currently deductible for tax purposes
10,608


 
75,782


     Other 
8,940


 
18,437


 
 
 
 
Total deferred tax assets
248,757


 
386,861


 
 
 
 
Deferred tax liabilities:
 


 
 


     Fixed assets cost recovery, net
(257,647
)
 
(240,463
)
     Other
(12,168
)
 
(10,524
)
 
 
 
 
Net deferred tax assets /(liabilities) before valuation allowance
(21,058
)
 
135,874


Valuation allowance
(44,562
)
 
(47,006
)
 
 
 
 
Net deferred tax assets/(liabilities)
$
(65,620
)
 
$
88,868






The valuation allowance decreased by $2.4 million in fiscal year 2011 primarily due to benefits realized for state research tax credit carryforwards. $37.4 million of the valuation allowance is attributable to the tax benefits of income tax deductions generated by the exercise of stock options that when realized, will be recorded as a credit to additional paid-in-capital.


As of June 25, 2011, the Company has $29.1 million of federal net operating loss carryforwards expiring at various dates between fiscal years 2024 and 2028, $57.7 million of state net operating loss carryforwards expiring at various dates through the fiscal years 2029, $22.5 million of foreign net operating losses with no expiration date, $8.3 million of state credit carryforwards expiring at various dates between fiscal years 2012 and 2026 and $62.9 million of state credit carryforwards with no expiration date.


The Company classifies unrecognized tax benefits as (i) a current liability to the extent that payment is anticipated within one year; (ii) a non current liability to the extent that payment is not anticipated within one year; or (iii) as a reduction to deferred tax assets to the extent that the unrecognized tax benefit relates to deferred tax assets such as operating loss or tax credit carryforwards.


A reconciliation of the change in gross unrecognized tax benefits, excluding interest, penalties and the federal benefit for state unrecognized tax benefits, is as follows:
 
 
For the Year Ended
 
 
June 25, 2011
 
June 26, 2010
 
 
(in thousands)
Balance as of beginning of year
 
$
151,464


 
$
137,298


Tax positions related to current year:
 
 
 
 
     Addition
 
59,345


 
31,491


Tax positions related to prior year:
 
 
 
 
     Addition
 
7,935


 
5,696


     Reduction
 
(21,399
)
 
(190
)
Settlements
 
(16,636
)
 
(22,831
)
Lapses in statutes of limitations
 
(63,296
)
 


 
 
 
 
 
Balance as of end of year
 
$
117,413


 
$
151,464






The total amount of gross unrecognized tax benefits as of June 25, 2011 that, if recognized, would affect the effective tax rate and additional paid in capital is $107.9 million and $9.5 million, respectively. During fiscal year 2011, $33.1 million of prior year unrecognized tax benefits were recognized, due to the lapse of the statute of limitations, and credited to additional paid in capital.


Consistent with prior years, the Company reports interest and penalties related to unrecognized tax benefits as a component of income tax expense. The gross amount of interest and penalties recognized in income tax expense during fiscal years ended June 25, 2011, June 26, 2010, and June 27, 2009 was $(17.1) million, $4.4 million and $5.5 million, respectively, and the total amount of interest and penalties accrued as of June 25, 2011, June 26, 2010, and June 27, 2009 was $3.3 million, $20.4 million, and $21.8 million, respectively. The fiscal year 2011 interest and penalty net benefit of $17.1 million is primarily due to a $19.5 million reversal of prior year interest and penalties due to the expiration of the statute of limitations.


Management estimates that it is reasonably possible that the liability for gross unrecognized tax benefits, including accrued interest and penalties, could decrease within the next 12 months by $3.4 million. Such changes could occur based on the expiration of various statutes of limitations and the possible conclusion of ongoing tax audits.


During the second quarter of fiscal year 2011 the Internal Revenue Service ("IRS") completed its examination of the Company's federal corporate income tax returns for the fiscal years 2007- 2008 and issued a Revenue Agents Report ("RAR"). The Company agreed with the RAR findings and made a payment of $0.8 million that reduced the Company's liability for unrecognized tax benefits. During the fourth quarter of fiscal year 2011, an examination of the Company's California corporate income tax returns for the fiscal years 2006 - 2007 was completed. The Company agreed with the examination results, which reduced California research tax credit carryforwards and unrecognized tax benefits by $14.5 million.


In the first quarter of fiscal year 2012 the IRS intends to commence an examination of the Company's federal corporate income tax returns for the fiscal years 2009 and 2010. Management believes that it has adequately provided for any adjustments that may result from the IRS examination, however, the outcome of tax examinations cannot be predicted with certainty.


A summary of the fiscal tax years that remain subject to examination, as of June 25, 2011, for the Company's major tax jurisdictions are:
United States - Federal
2008 - forward
United States - Various States
2007 - forward
Japan
2006 - forward
Philippines
2008 - forward
Thailand
2009 - forward
United Kingdom
2008 - forward