Income Taxes

6 Months Ended

Jun. 15, 2019

Income Tax Disclosure [Abstract]

Income Taxes

Income Taxes

Tax Cuts and Jobs Act

During the fourth quarter of 2017, the TCJ Act was enacted in the United States. Among its many provisions, the TCJ Act imposed a mandatory one-time transition tax on undistributed international earnings and reduced the U.S. corporate income tax rate from 35% to 21%, effective January 1, 2018.

The U.S. Securities and Exchange Commission previously issued guidance related to the TCJ Act which allowed recording of provisional tax expense using a measurement period, not to exceed one year, when information necessary to complete the accounting for the effects of the TCJ Act was not available. We elected to apply the measurement period provisions of this guidance to certain income tax effects of the TCJ Act when it became effective in the fourth quarter of 2017. The provisional measurement period ended in the fourth quarter of 2018. As a result, we recognized a net tax benefit of $28 million ($0.02 per share) for the fiscal year ended December 29, 2018, which included provisional transition tax expense of $777 million ($0.54 per share) recorded in the 12 weeks ended June 16, 2018 and $778 million ($0.54 per share) recorded in the 24 weeks ended June 16, 2018.

While our accounting for the recorded impact of the TCJ Act as of December 29, 2018 was deemed to be complete, this amount was based on prevailing regulations and available information as of December 29, 2018, and additional guidance issued by the Internal Revenue Service (IRS) impacted, and may continue to impact, our recorded amounts after December 29, 2018.

In the 24 weeks ended June 15, 2019, we recognized tax benefits totaling $29 million ($0.02 per share) in connection with the TCJ Act, including the impact of additional guidance issued by the IRS in the first quarter of 2019.

For further information and discussion of the impact of the TCJ Act, refer to Note 5 to our consolidated financial statements in our 2018 Form 10-K.

Other Tax Matters

In a referendum held on May 19, 2019, Switzerland passed the Federal Act on Tax Reform and AHV Financing (TRAF), effective January 1, 2020. The TRAF did not have a material impact on our business and financial results for the 12 and 24 weeks ended June 15, 2019. Enactment of TRAF provisions subsequent to our second quarter of 2019 is expected to result in adjustments to our financial statements and related disclosures in future periods. We will continue to monitor and assess the impact the TRAF may have on our business and financial results.

In the second quarter of 2018, we reached an agreement with the IRS resolving all open matters related to the audits of taxable years 2012 and 2013. The agreement resulted in a non-cash tax benefit totaling $314 million ($0.22 per share) in the 12 and 24 weeks ended June 16, 2018.