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Income Taxes
12 Months Ended
Jan. 31, 2017
Income Tax Disclosure [Abstract]  
Income Taxes
NOTE 8 — INCOME TAXES
Significant components of the provision for income taxes are as follows (in thousands):  
Year ended January 31:
2017
 
2016
 
2015
Current tax expense:
 
 
 
 
 
Federal
$
37,724

 
$
71,502

 
$
32,988

State
4,030

 
5,989

 
1,626

Foreign
30,914

 
36,804

 
29,733

Total current tax expense
72,668

 
114,295

 
64,347

Deferred tax (benefit) expense:
 
 
 
 
 
Federal
(8,380
)
 
(3,984
)
 
6,391

State
(799
)
 
543

 
281

Foreign
(1,823
)
 
5,828

 
(7,007
)
Total deferred tax (benefit) expense
(11,002
)
 
2,387

 
(335
)
 
$
61,666

 
$
116,682

 
$
64,012


The reconciliation of the U.S. federal statutory tax rate to the effective tax rate is as follows:
Year ended January 31:
2017
 
2016
 
2015
U.S. statutory rate
35.0
 %
 
35.0
 %
 
35.0
 %
State income taxes, net of federal benefit
0.8

 
1.1

 
0.5

Net changes in deferred tax valuation allowances
(3.4
)
 
0.0

 
(4.5
)
Tax on foreign earnings different than U.S. rate
(9.9
)
 
(7.4
)
 
(11.8
)
Nondeductible interest
2.1

 
1.6

 
4.0

Reserve established for foreign income tax contingencies
0.5

 
0.0

 
0.1

Effect of company-owned life insurance
(0.7
)
 
0.2

 
(0.4
)
Undistributed earnings on foreign assets held for sale
0.0

 
0.0

 
2.4

Other, net
(0.4
)
 
0.0

 
1.5

 
24.0
 %
 
30.5
 %
 
26.8
 %

In fiscal 2017 and 2015, the Company recorded income tax benefits of $12.5 million and $19.2 million, respectively, primarily related to the reversal of deferred tax valuation allowances in certain European jurisdictions which had been recorded in prior fiscal years. Additionally during fiscal 2015, the Company recorded a $5.6 million deferred tax liability related to undistributed earnings on assets held for sale in certain Latin American jurisdictions (see further discussion in Note 6 – Loss on Disposal of Subsidiaries).
The components of pretax income are as follows (in thousands):
Year ended January 31:
2017
 
2016
 
2015
United States
$
92,067

 
$
195,219

 
$
100,166

Foreign
164,694

 
187,199

 
139,018

 
$
256,761

 
$
382,418

 
$
239,184


The significant components of the Company’s deferred tax liabilities and assets are as follows (in thousands):
As of January 31:
2017
 
2016
Deferred tax liabilities:
 
 
 
Depreciation and amortization
$
48,910

 
$
53,939

Capitalized marketing program costs
7,525

 
6,547

Goodwill
7,581

 
8,545

Deferred costs currently deductible
4,110

 
5,415

Other, net
5,241

 
5,938

Total deferred tax liabilities
73,367

 
80,384

Deferred tax assets:
 
 
 
Accrued liabilities
41,509

 
42,071

Loss carryforwards
92,338

 
103,647

Amortizable goodwill
2,191

 
5,315

Depreciation and amortization
4,547

 
6,502

Disallowed interest expense
6,249

 
5,140

Acquisition and transaction related costs
5,605

 

Other, net
10,928

 
9,659

 
163,367

 
172,334

Less: valuation allowances
(46,764
)
 
(60,165
)
Total deferred tax assets
116,603

 
112,169

Net deferred tax asset
$
43,236

 
$
31,785


The net change in the deferred tax valuation allowances in fiscal 2017 was a decrease of $13.4 million primarily resulting from the reversal of deferred tax valuation allowances related to certain European jurisdictions as discussed previously. The net change in the deferred tax valuation allowances in fiscal 2016 was a decrease of $11.3 million primarily due to the impact of the translation of foreign currencies and the utilization of deferred tax assets subject to valuation allowances.
The valuation allowances at both January 31, 2017 and 2016 primarily relate to foreign net operating loss carryforwards. The Company’s net operating loss carryforwards totaled $432.8 million and $482.3 million at January 31, 2017 and 2016, respectively. The majority of the net operating losses have an indefinite carryforward period with the remaining portion expiring in fiscal years 2018 through 2034. The Company considers all positive and negative evidence available in determining the potential of realizing deferred tax assets. To the extent that the Company generates consistent taxable income within those operations with valuation allowances, the Company may reduce the valuation allowances, thereby reducing income tax expense and increasing net income in the period the determination is made.
The estimates and assumptions used by the Company in computing the income taxes reflected in the Company’s consolidated financial statements could differ from the actual results reflected in the income tax returns filed during the subsequent year. Adjustments are recorded based on filed returns when such returns are finalized or the related adjustments are identified.
At January 31, 2017, there are $776.9 million of consolidated cumulative undistributed earnings of foreign subsidiaries for which no deferred taxes have been recorded. It is not practical to estimate the amount of unrecognized deferred U.S. income tax that might be payable if any earnings were to be distributed by individual foreign subsidiaries.
A reconciliation of the beginning and ending balances of the total amount of gross unrecognized tax benefits, excluding accrued interest and penalties, for the years ended January 31, 2017, 2016 and 2015 is as follows (in thousands):
 
For the year ended January 31:
2017
 
2016
 
2015
Gross unrecognized tax benefits at beginning of period
$
12,989

 
$
5,125

 
$
5,859

Increases in tax positions for prior years
5,443

 
8,443

 
845

Decreases in tax positions for prior years
(118
)
 
(348
)
 
(730
)
Increases in tax positions for current year
1,022

 
106

 
105

Expiration of statutes of limitation
(292
)
 
(77
)
 
(63
)
Settlements
(370
)
 
(104
)
 

Changes due to translation of foreign currencies
(369
)
 
(156
)
 
(891
)
Gross unrecognized tax benefits at end of period
$
18,305

 
$
12,989

 
$
5,125



At January 31, 2017, 2016 and 2015, the amount of unrecognized tax benefits that, if recognized, would impact the effective tax rate was $12.5 million, $10.1 million and $5.1 million, respectively.
Unrecognized tax benefits that have a reasonable possibility of significantly decreasing within the 12 months following January 31, 2017 totaled $4.8 million and were primarily related to the foreign taxation of certain transactions. Consistent with prior periods, the Company recognizes interest and penalties related to unrecognized tax benefits in the provision for income taxes. The Company’s accrued interest at January 31, 2017, would not have a material impact on the effective tax rate if reversed. The provision for income taxes for each of the fiscal years ended January 31, 2017, 2016 and 2015 includes interest expense on unrecognized income tax benefits for current and prior years which is not significant to the Company’s Consolidated Statement of Income. The change in the balance of accrued interest for fiscal 2017, 2016 and 2015, includes the current year end accrual, an interest benefit resulting from the expiration of statutes of limitation, and the translation adjustments on foreign currencies.
The Company conducts business primarily in the Americas and Europe and, as a result, one or more of its subsidiaries files income tax returns in the U.S. federal, various state, local and foreign tax jurisdictions. In the normal course of business, the Company is subject to examination by taxing authorities. The Company is no longer subject to examinations by the Internal Revenue Service for years before fiscal 2014. Income tax returns of various foreign jurisdictions for fiscal 2006 and forward are currently under taxing authority examination or remain subject to audit.