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Income Taxes (Notes)
9 Months Ended
Oct. 31, 2018
Income Taxes [Abstract]  
Income Tax Disclosure [Text Block]
NOTE 8 — INCOME TAXES

U.S. Tax Reform
On December 22, 2017, the U.S. federal government enacted the U.S. Tax Cuts and Jobs Act (“U.S. Tax Reform”) which significantly revised U.S. corporate income tax law by, among other things, reducing the U.S. federal corporate income tax rate from 35% to 21% and implementing a modified territorial tax system that includes a one-time transition tax on deemed repatriated earnings of foreign subsidiaries. Due to the complexities involved in accounting for U.S. Tax Reform, the SEC issued Staff Accounting Bulletin (“SAB”) 118 which requires that the Company include in its financial statements the reasonable estimate of the impact of U.S. Tax Reform on earnings to the extent such reasonable estimate has been determined. SAB 118 allows the Company to report provisional amounts within a measurement period up to one year due to the complexities inherent in adopting the changes. In the fourth quarter of fiscal 2018, the Company recorded income tax expense of $95.4 million, which represented the Company’s reasonable estimate of the impact of the enactment of U.S. Tax Reform. The amounts recorded include income tax expense of $101.1 million for the one-time transition tax and a net income tax benefit of $5.7 million related to the remeasurement of net deferred tax liabilities as a result of the change in the U.S. federal corporate income tax rate.
During the three and nine months ended October 31, 2018, the Company decreased its provisional estimate of the one-time transition tax by $24.0 million upon further analysis of earnings and profits of the Company's foreign subsidiaries and utilization of foreign tax credits. The Company considers both the recognition of the transition tax and the remeasurement of deferred taxes incomplete. The final impact from the enactment of U.S. Tax Reform may differ from the reasonable estimate of $71.4 million due to substantiation of foreign-based earnings and profits and foreign tax credits and the utilization of those foreign tax credits. Additionally, new guidance from regulators, interpretation of the law, and refinement of the Company’s estimates from ongoing analysis of data and tax positions may further change the provisional amounts recorded. Any further changes in the provisional amount recorded will be reflected in income tax expense in the period they are identified. Additionally, U.S. Tax Reform subjects a U.S. shareholder to tax on Global Intangible Low-Taxed Income (“GILTI”) earned by certain foreign subsidiaries. The Company can make an accounting policy election to either treat taxes due on the GILTI as a current period expense, or factor such amounts into its measurement of deferred taxes. Given the complexity of the GILTI provisions, the Company is still evaluating these matters and has not yet determined its accounting policy. However, the Company has included tax expense related to GILTI for current year operations in the estimated annual effective tax rate and has not provided for GILTI on deferred items.
Tax Indemnifications

In connection with the acquisition of TS, pursuant to the interest purchase agreement, the Company and Avnet agreed to indemnify each other in relation to certain tax matters. As a result, the Company has recorded certain indemnification assets and liabilities for expected amounts to be received from and paid to Avnet. During the three and nine months ended October 31, 2018, due to the resolution of a pre-acquisition tax matter in a jurisdiction in which the Company operates, the Company recorded a benefit in income tax expense of $5.5 million and $6.1 million, respectively. As a result, the Company recorded expenses to recognize the corresponding indemnification liability of $5.5 million and $6.1 million during the three and nine months ended October 31, 2018, respectively, which is included in “selling, general and administrative expenses” in the Consolidated Statement of Income. The net impact of these items had no impact on the Company’s net income.
Effective Tax Rate
The Company's effective tax rate was 2.0% and 32.1% for the three months ended October 31, 2018 and 2017, respectively, and 7.0% and 33.8% for the nine months ended October 31, 2018 and 2017, respectively. On an absolute dollar basis, the provision for income taxes decreased to $2.3 million for the third quarter of fiscal 2019 compared to $17.6 million for the third quarter of fiscal 2018 and decreased to $16.8 million for the nine months ended October 31, 2018 compared to $59.0 million for the nine months ended October 31, 2017. The decrease in the effective tax rate and the provision for income taxes for the three and nine months ended October 31, 2018, as compared to the prior year, is primarily due to the decrease in the provisional estimate of the one-time transition tax related to U.S. Tax Reform, the impact of the resolution of a pre-acquisition tax matter related to TS, the decrease in the U.S. federal income tax rate partially offset by GILTI provisions due to U.S. Tax Reform and the relative mix of earnings and losses within the taxing jurisdictions in which the Company operates. The decrease in both the effective tax rate and the provision for income taxes for the nine months ended October 31, 2018, is also impacted by income tax benefits recorded in relation to the settlement agreement reached with Avnet of $13.0 million (see Note 4 – Acquisitions for further discussion).