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Income Taxes
12 Months Ended
Mar. 31, 2012
Income Taxes [Abstract]  
Income Taxes

Note 16. Income Taxes

The provision for income taxes consists of the following:

 

                         
(In thousands)   2012     2011     2010  

Federal:

                       

Current

  $ (17,333   $ 14,172     $ (8,732

Deferred

    74,911       95,660       56,085  
   

 

 

   

 

 

   

 

 

 
      57,578       109,832       47,353  
   

 

 

   

 

 

   

 

 

 

State:

                       

Current

    (2,999     2,365       6,174  

Deferred

    6,591       13,240       243  
   

 

 

   

 

 

   

 

 

 
      3,592       15,605       6,417  
   

 

 

   

 

 

   

 

 

 

Foreign:

                       

Current

    7,978       3,107       8,809  

Deferred

    (2,176     661       1,702  
   

 

 

   

 

 

   

 

 

 
      5,802       3,768       10,511  
   

 

 

   

 

 

   

 

 

 

Total

  $ 66,972     $ 129,205     $ 64,281  
   

 

 

   

 

 

   

 

 

 

The domestic and foreign components of income before income taxes were as follows:

 

                         
(In thousands)   2012     2011     2010  

Domestic

  $ 74,959     $ 161,784     $ 59,473  

Foreign

    522,092       609,296       362,292  
   

 

 

   

 

 

   

 

 

 

Income before income taxes

  $ 597,051     $ 771,080     $ 421,765  
   

 

 

   

 

 

   

 

 

 

The tax benefits (expenses) associated with stock option exercises and the employee stock purchase plan recorded in additional paid-in capital were $9.9 million, $4.9 million and $(4.4) million, for fiscal 2012, 2011 and 2010, respectively.

As of March 31, 2012, the Company had federal and state net operating loss carryforwards of approximately $25.9 million. If unused, these carryforwards will expire in 2014 through 2030. All of the federal and state net operating loss carryforwards are subject to change of ownership limitations provided by the Internal Revenue Code and similar state provisions. The Company had federal and state research tax credit carryforwards of approximately $138.4 million and federal affordable housing tax credit carryforwards of approximately $9.3 million. If unused, $32.1 million of the tax credit carryforwards will expire in 2021 through 2032. The remainder of the credits has no expiration date. Some of the federal and state credit carryforwards are subject to change of ownership limitations provided by the Internal Revenue Code and similar state provisions.

Unremitted foreign earnings that are considered to be permanently invested outside the U.S. and on which no U.S. taxes have been provided, are approximately $1.67 billion as of March 31, 2012. The residual U.S. tax liability, if such amounts were remitted, would be approximately $544.3 million.

 

The provision for income taxes reconciles to the amount derived by applying the Federal statutory income tax rate to income before provision for taxes as follows:

 

                         
(In thousands)   2012     2011     2010  

Income before provision for taxes

  $ 597,051     $ 771,080     $ 421,765  

Federal statutory tax rate

    35     35     35
   

 

 

   

 

 

   

 

 

 

Computed expected tax

    208,968       269,878       147,618  

State taxes, net of federal benefit

    2,162       10,317       4,527  

Non-deductible stock-based compensation

    2,658       2,220       1,813  

Tax exempt interest

    (263     (152     (396

Foreign earnings at lower tax rates

    (117,013     (131,261     (67,651

Tax credits

    (29,633     (17,431     (16,491

Deferred compensation

    76       (1,297     (2,994

Other

    17       (3,069     (2,145
   

 

 

   

 

 

   

 

 

 

Provision for income taxes

  $ 66,972     $ 129,205     $ 64,281  
   

 

 

   

 

 

   

 

 

 

The Company has manufacturing operations in Singapore where the Company has been granted “Pioneer Status” that is effective through fiscal 2021. The Pioneer Status reduces the Company’s tax on the majority of Singapore income from 17% to zero. The benefit of Pioneer Status in Singapore for fiscal 2012, fiscal 2011 and fiscal 2010 are approximately $43.5 million ($0.16 per diluted share), $54.8 million ($0.21 per diluted share) and $18.7 million ($0.07 per diluted share), respectively, on income considered permanently reinvested outside the U.S. The tax effect of operations in low tax jurisdictions on the Company’s overall tax rate is reflected in the table above.

 

The major components of deferred tax assets and liabilities consisted of the following as of March 31, 2012 and April 2, 2011:

 

                 
(In thousands)   2012     2011  

Deferred tax assets:

               

Inventory valuation differences

  $ 498     $ 1,490  

Stock-based compensation

    29,451       29,755  

Deferred income on shipments to distributors

    10,493       19,580  

Accrued expenses

    39,942       42,735  

Tax loss carryforwards

    3,856       8,508  

Tax credit carryforwards

    97,104       84,694  

Intangible and fixed assets

    4,115       7,547  

Strategic and equity investments

    7,313       9,198  

Deferred compensation plan

    17,423       16,503  

Other

    3,634       3,470  
   

 

 

   

 

 

 
      213,829       223,480  

Valuation allowance

    (28,963     (17,841
   

 

 

   

 

 

 

Total deferred tax assets

    184,866       205,639  
   

 

 

   

 

 

 

Deferred tax liabilities:

               

Unremitted foreign earnings

    (308,017     (264,230

State income taxes

    (17,343     (17,842

Convertible debt

    (192,397     (178,178

Other

    (8,605     (4,257
   

 

 

   

 

 

 

Total deferred tax liabilities

    (526,362     (464,507
   

 

 

   

 

 

 

Total net deferred tax liabilities

  $ (341,496   $ (258,868
   

 

 

   

 

 

 

Long-term deferred tax assets of $56.7 million and $57.3 million as of March 31, 2012 and April 2, 2011, respectively, were included in other assets on the consolidated balance sheet. Current deferred tax liabilities of zero and $404 thousand as of March 31, 2012 and April 2, 2011, respectively, were included in other accrued liabilities on the consolidated balance sheet.

As of March 31, 2012, gross deferred tax assets were offset by valuation allowances of $29.0 million, all of which was associated with state tax credit carryforwards.

The aggregate changes in the balance of gross unrecognized tax benefits for fiscal 2012 and 2011 were as follows:

 

                 
(In thousands)   2012     2011  

Balance as of beginning of fiscal year

  $ 79,690     $ 96,269  

Increases in tax positions for prior years

    56       11,964  

Decreases in tax positions for prior years

    (653     (20,030

Increases in tax positions for current year

    3,768       2,588  

Settlements

    (39     (6,749

Lapse in statute of limitations

    (17,784     (4,352
   

 

 

   

 

 

 

Balance as of end of fiscal year

  $ 65,038     $ 79,690  
   

 

 

   

 

 

 

If the remaining balance of $65.0 million and $79.7 million of unrecognized tax benefits as of March 31, 2012 and April 2, 2011, respectively, were realized in a future period, it would result in a tax benefit of $41.7 million and $56.0 million, respectively, thereby reducing the effective tax rate.

The Company’s policy is to include interest and penalties related to income tax liabilities within the provision for income taxes on the consolidated statements of income. The balance of accrued interest and penalties was $839 thousand and $2.2 million as of March 31, 2012 and April 2, 2011, respectively. Interest and penalties released from the Company’s provision for income taxes totaled $644 thousand, $840 thousand and $900 thousand for fiscal 2012, 2011 and 2010, respectively.

 

The Company is no longer subject to U.S. federal audits by taxing authorities for years through fiscal 2008. The Company is no longer subject to U.S. state audits for years through fiscal 2004, except for fiscals 1996 through 2001 which are still open for audit purposes. The Company is no longer subject to tax audits in Ireland for years through fiscal 2007.

It is reasonably possible that changes to our unrecognized tax benefits could be significant in the next twelve months due to tax audit settlements and lapses of statutes of limitation. As a result of uncertainties regarding tax audit settlements and their possible outcomes, an estimate of the range of increase or decrease that could occur in the next twelve months cannot be made.