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Income Taxes
3 Months Ended
Jul. 03, 2021
Income Tax Disclosure [Abstract]  
Income Taxes Income Taxes
The Company recorded a tax provision of $5.0 million for the first quarter of fiscal 2022 as compared to $69.5 million in the same prior year period, representing effective tax rates of 2% and 43%, respectively.

The difference between the U.S. federal statutory tax rate of 21% and the Company's effective tax rate in the first quarter of fiscal 2022 was primarily due to the beneficial impact of income earned in lower tax rate jurisdictions and excess tax benefits with respect to stock-based compensation, which was partially offset by the U.S. tax on global intangible low-taxed income (GILTI). The difference between the U.S. federal statutory tax rate of 21% and the Company's effective tax rate in the first quarter of fiscal 2021 was primarily due to the beneficial impact of income earned in lower tax rate jurisdictions, which was partially offset by GILTI and the recognition of the cumulative adverse impact of including stock-based compensation in the intercompany research and development (R&D) cost sharing arrangement.

During fiscal 2021, the U.S. Supreme Court (Supreme Court) denied certiorari of the Ninth Circuit Court of Appeals (Ninth Circuit) decision in the case of Altera Corp. v. Commissioner (Altera), which concerned related party R&D cost sharing arrangements and required stock-based compensation to be included in the pool of costs to be shared. While the Company is not a party to the case, it is subject to the findings. Pursuant to the Supreme Court’s decision not to review the case, the Company recorded expense during fiscal 2021 for taxes and interest representing the cumulative adverse impact. Despite the decision in the Altera tax case, the Company has concluded that the related law remains unsettled and will continue to monitor developments and the potential effect on its condensed consolidated financial statements and tax filings.

The Company’s total gross unrecognized tax benefits as of July 3, 2021, determined in accordance with authoritative guidance for measuring uncertain tax positions, increased by $8.1 million in the first quarter of fiscal 2022 to $153.1 million. The total amount of unrecognized tax benefits that, if realized in a future period, would favorably affect the effective tax rate was $114.3 million as of July 3, 2021.
The Company’s policy is to include interest and penalties related to income tax liabilities within the provision for income taxes on the condensed consolidated statements of income. The balance of accrued interest and penalties recorded in the condensed consolidated balance sheets was $3.9 million as of July 3, 2021 compared to $3.7 million in the same prior year period. The amounts of interest and penalties included in the Company's provision for income taxes were not material for all periods presented.

The statutes of limitations have closed for U.S. federal income tax purposes for years through fiscal 2017 and for significant U.S. state income tax purposes for years through fiscal 2014. The statutes of limitations have closed for Ireland and India income tax purposes for years through fiscal 2016 and for Singapore income tax purposes for years through fiscal 2015.