XML 25 R15.htm IDEA: XBRL DOCUMENT v3.20.2
Note I - Income Taxes
3 Months Ended
Sep. 30, 2020
Notes to Financial Statements  
Income Tax Disclosure [Text Block]
I
. Income Taxes
 
Our effective tax rate for the
three
months ended
September 30, 2020
was (
28.0%
). Our effective rates differ from the fiscal
2021
U.S. federal statutory rate of
21%
primarily due to a discrete tax benefit discussed below. Our effective tax rate for the
three
months ended
September 30, 2019
was
21.3%.
 
To determine our quarterly provision for income taxes, we use an estimated annual effective tax rate, which is based on expected annual income, statutory tax rates and tax planning opportunities available in the various jurisdictions to which we are subject. Certain significant or unusual items are separately recognized in the quarter in which they occur and can be a source of variability in the effective tax rate from quarter to quarter. We recognize interest and penalties related to uncertain tax positions, if any, as an income tax expense.
 
The Coronavirus Aid, Relief, and Economic Security Act (“CARES Act”) was enacted on
March 27, 2020
in the United States. The CARES Act and related notices include several significant provisions, including delaying certain payroll tax payments, mandatory transition tax payments under the Tax Cuts and Jobs Act (“TCJ Act”), and estimated income tax payments. The CARES Act also allows net operating losses (NOL) to be carried back
five
years.  We expect to use this carryback period for the NOL generated with our
June 30, 2020
federal tax return, and have recorded a discrete tax benefit in the current quarter, as discussed below.
 
On
July 23, 2020,
the Department of Treasury issued final regulations which provide an exclusion to the global intangible low-taxed income (GILTI) calculation on an elective basis.  These regulations were effective
September 21, 2020
and
may
be retroactively. Under these new regulations, we are able to exclude the GILTI calculation from our domestic taxable income if the deemed effective tax rate at our foreign subsidiary is greater than
18.9%.
  We assessed this rate, including the implementation of certain tax strategies, and we have determined that our effective rate at NAIE is greater than
18.9%
as of the year ending
June 30, 2020. 
We reassessed our estimated taxes for fiscal
2020
and in the
three
months ended
September 30, 2020
we recorded a reduction to our fiscal
2020
estimated taxes of
$0.4
million as a discrete benefit.  As a result of this adjustment, we now expect our domestic tax return will reflect a net operating loss and, in accordance with the CARES ACT, we plan on carrying this loss back to fiscal
2015,
which reflected a higher federal tax rate.  Due to this rate differential we have recorded a permanent discrete tax benefit of
$0.3
million during the
three
months ended
September 30, 2020. 
As a result of this tax planning strategy for NAIE, during the
three
months ended
September 30, 2020
we have recorded additional foreign estimated tax expense of
$0.4
million and we have reversed our deferred tax liability of
$0.5
million.
 
We record valuation allowances to reduce our deferred tax assets to an amount we believe is more likely than
not
to be realized. In assessing the realizability of deferred tax assets, management considers whether it is more likely than
not
that some portion or all of the deferred tax assets will be realized. The ultimate realization of deferred tax assets is dependent upon the generation of future taxable income during the periods in which those temporary differences become deductible. During the
three
months ended
September 30, 2020,
there was
no
change to our valuation allowance for our deferred tax assets.
 
Income taxes are accounted for under the asset and liability method. Deferred tax assets and liabilities are measured using enacted tax rates for each of the jurisdictions in which we operate. Deferred tax assets and liabilities are expected to apply to taxable income in the years in which those temporary differences are expected to be recovered or settled using the tax rates then in effect. The effect on deferred tax assets and liabilities of a change in tax rates is recognized as income or expense in the period that includes the enactment date for such new rates.
 
We are subject to taxation in Switzerland and in the U.S. at the federal level and in various state jurisdictions. Our tax years for the fiscal year ended
June 30,
2017
and forward are subject to examination by the U.S. tax authorities. Our tax years for the fiscal years ended
June 30,
2007
and forward are subject to examination by the state tax authorities. Our tax years for the fiscal year ended
June 30,
2019
and forward are subject to examination by the Swiss tax authorities.
 
It is our policy to establish reserves based on management's assessment of exposure for certain positions taken in previously filed tax returns that
may
become payable upon audit by tax authorities. Our tax reserves are analyzed quarterly, and adjustments are made as events occur that we believe warrant adjustments to those reserves. There were
no
adjustments to reserves in the
three
month periods ended
September 30, 2020.