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Income Taxes
6 Months Ended
Mar. 31, 2018
Income Tax Disclosure [Abstract]  
Income Taxes
Income Taxes
On December 22, 2017, the U.S. Tax Cuts & Jobs Act was enacted ("Tax Reform"). Due to the complexities in implementing Tax Reform, the SEC issued Staff Accounting Bulletin 118, which allows the Company to record a provisional tax expense when uncertainty or other factors may impact the final outcome. In accordance with U.S. GAAP, which requires the Company to recognize the effects of Tax Reform in the period of enactment, $124.5 million of tax expense was recorded during the three months ended December 30, 2017. The $124.5 million included $101.8 million of U.S. federal and state taxes on the deemed repatriation of undistributed foreign earnings, which are payable over an eight year period beginning in fiscal 2019, and $22.7 million of foreign withholding taxes due to a change in the Company's permanently reinvested assertion on certain foreign earnings that are payable upon repatriation to the U.S. The Company continues to believe this is a reasonable estimate of tax expense related to Tax Reform using all analyses, interpretations and guidance available at this time. The Company continues to assess the impact of Tax Reform, and the final impact may differ from this estimate, perhaps materially, due to, among other things, changes in interpretations, assumptions, and/or guidance that may be issued in the near future or actions the Company may take as a result. For the three months ended March 31, 2018, there have been no changes in interpretations, assumptions and/or guidance that require an adjustment to the provisional tax expense the Company recorded during the three months ended December 30, 2017.
As of March 31, 2018, the Company reported outstanding liabilities of $121.8 million for Tax Reform, of which $91.9 million is recorded in "Long-term accrued income taxes payable", $20.0 million is recorded in "Deferred income tax liabilities" and $9.9 million is recorded in “Other accrued liabilities” in the accompanying Condensed Consolidated Balance Sheet. The total outstanding liabilities are lower than the Tax Reform expense of $124.5 million for the three months ended December 30, 2017 due to withholding taxes paid on dividends and the related foreign exchange impact during the three months ended March 31, 2018, which are recorded in "Miscellaneous other income (expense)" in the accompanying Condensed Consolidated Statements of Comprehensive Income (Loss).
Income tax expense for the three and six months ended March 31, 2018 was $2.4 million and $130.0 million, respectively. For the six months ended March 31, 2018, the tax expense of $130.0 million includes $124.5 million due to the impact of Tax Reform recorded during the three months ended December 30, 2017. Income tax expense for the three and six months ended April 1, 2017 was $3.1 million and $6.0 million, respectively.
The effective tax rates for the three and six months ended March 31, 2018 were 16.5% and 297.0%, respectively, compared to the effective tax rates of 9.6% and 9.4% for the three and six months ended April 1, 2017, respectively. The effective tax rate for the three months ended March 31, 2018 increased from the effective tax rate for the three months ended April 1, 2017, primarily due to a $13.5 million one-time bonus paid to full-time, non-executive employees ("one-time employee bonus") during the three months ended March 31, 2018, and a decrease in pre-tax earnings in jurisdictions where the Company maintains a valuation allowance. The effective tax rate for the six months ended March 31, 2018 increased from the effective tax rate for the six months ended April 1, 2017, primarily due to the impact of Tax Reform, the one-time employee bonus and a decrease in pre-tax earnings in jurisdictions where the Company maintains a valuation allowance.
There were no material additions to the amount of unrecognized tax benefits recorded for uncertain tax positions as of March 31, 2018, as compared to September 30, 2017. The Company recognizes accrued interest and penalties on uncertain tax positions as a component of income tax expense. The amount of interest and penalties recorded for the three and six months ended March 31, 2018 was not material.
One or more uncertain tax positions may be settled within the next 12 months. Settlement of these matters is not expected to have a material effect on the Company's consolidated results of operations, financial position and cash flows. The Company is not currently under examination by taxing authorities in the U.S. or any foreign jurisdictions in which the Company operates.
The Company maintains valuation allowances when it is more likely than not that all or a portion of a net deferred tax asset will not be realized. During the three months ended March 31, 2018, the Company continued to record a full valuation allowance against its net deferred tax assets in certain jurisdictions within the AMER and EMEA segments, as it was more likely than not that these assets would not be fully realized based primarily on historical performance. The Company will continue to provide a valuation allowance against its net deferred tax assets in each of the applicable jurisdictions going forward until it determines it is more likely than not that the deferred tax assets will be realized.