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Income Taxes
12 Months Ended
Mar. 31, 2019
Income Tax Disclosure [Abstract]  
Income Taxes

Note 8 — Income Taxes

The components of (loss) income before income taxes by jurisdiction are as follows:

 

 

 

Fiscal Years Ended

 

 

 

March 31,

2019

 

 

March 31,

2018

 

 

March 31,

2017

 

 

 

(In thousands)

 

United States

 

$

(102,643

)

 

$

(92,767

)

 

$

29,649

 

Foreign

 

 

(7,838

)

 

 

(12,703

)

 

 

(4,265

)

 

 

$

(110,481

)

 

$

(105,470

)

 

$

25,384

 

 

The benefit from (provision for) income taxes includes the following:

 

 

 

Fiscal Years Ended

 

 

 

March 31,

2019

 

 

March 31,

2018

 

 

March 31,

2017

 

 

 

(In thousands)

 

Current tax provision

 

 

 

 

 

 

 

 

 

 

 

 

Federal

 

$

(821

)

 

$

(284

)

 

$

(2,041

)

State

 

 

(690

)

 

 

(401

)

 

 

(1,167

)

Foreign

 

 

(1,619

)

 

 

(953

)

 

 

(600

)

 

 

 

(3,130

)

 

 

(1,638

)

 

 

(3,808

)

Deferred tax benefit (provision)

 

 

 

 

 

 

 

 

 

 

 

 

Federal

 

 

34,099

 

 

 

24,833

 

 

 

(4,410

)

State

 

 

8,738

 

 

 

10,450

 

 

 

4,509

 

Foreign

 

 

1,307

 

 

 

1,572

 

 

 

92

 

 

 

 

44,144

 

 

 

36,855

 

 

 

191

 

Total benefit from (provision for) income taxes

 

$

41,014

 

 

$

35,217

 

 

$

(3,617

)

 

Significant components of the Company’s net deferred tax assets are as follows:

 

 

 

As of

 

 

 

March 31,

2019

 

 

March 31,

2018

 

 

 

(In thousands)

 

Deferred tax assets:

 

 

 

 

 

 

 

 

Net operating loss carryforwards

 

$

197,486

 

 

$

184,177

 

Tax credit carryforwards

 

 

220,060

 

 

 

189,970

 

Other

 

 

57,246

 

 

 

52,958

 

Deferred revenue

 

 

24,421

 

 

 

1,127

 

Valuation allowance

 

 

(33,499

)

 

 

(29,049

)

Total deferred tax assets

 

 

465,714

 

 

 

399,183

 

Deferred tax liabilities:

 

 

 

 

 

 

 

 

Intangible assets

 

 

(72,776

)

 

 

(73,403

)

Property, equipment and satellites

 

 

(113,188

)

 

 

(96,661

)

Other

 

 

(21,160

)

 

 

(7,709

)

Total deferred tax liabilities

 

 

(207,124

)

 

 

(177,773

)

Net deferred tax assets

 

$

258,590

 

 

$

221,410

 

 

A reconciliation of the benefit from (provision for) income taxes to the amount computed by applying the statutory federal income tax rate to (loss) income before income taxes is as follows:

 

 

 

Fiscal Years Ended

 

 

 

March 31,

2019

 

 

March 31,

2018

 

 

March 31,

2017

 

 

 

(In thousands)

 

Tax benefit (provision) at federal statutory rate

 

$

23,201

 

 

$

22,149

 

 

$

(8,885

)

State tax benefit (provision), net of federal benefit

 

 

1,815

 

 

 

2,605

 

 

 

(1,681

)

Tax credits, net of valuation allowance

 

 

26,836

 

 

 

21,898

 

 

 

15,121

 

Non-deductible compensation

 

 

(4,527

)

 

 

(2,852

)

 

 

(2,659

)

Non-deductible transaction costs

 

 

(70

)

 

 

 

 

(645

)

Non-deductible meals and entertainment

 

 

(929

)

 

 

(727

)

 

 

(794

)

Stock-based compensation

 

 

180

 

 

 

799

 

 

 

(886

)

Change in federal tax rate due to Tax Reform

 

 

 

 

(5,335

)

 

 

Change in state effective tax rate

 

 

(684

)

 

 

(235

)

 

 

(417

)

Foreign effective tax rate differential, net of

   valuation allowance

 

 

(1,552

)

 

 

(2,054

)

 

 

(2,391

)

Unremitted subsidiary gains

 

 

(1,388

)

 

 

(864

)

 

 

162

 

Other

 

 

(1,868

)

 

 

(167

)

 

 

(542

)

Total benefit from (provision for) income taxes

 

$

41,014

 

 

$

35,217

 

 

$

(3,617

)

 

Effective January 1, 2018, the Tax Reform reduced the corporate federal income tax rate from 35% to 21%. The Company applied the 21% federal tax rate in the rate reconciliation for fiscal year 2019 and 2018. As the Company has a March 31 fiscal year-end, the phase-in of tax rate from 35% to 21% in fiscal year 2018 resulted in a blended tax rate of 31.6%. However, the Company applied the 21% federal tax rate in the rate reconciliation for fiscal year 2018 as the fiscal year 2018 taxable loss will not be subject to federal tax at the 31.6% blended tax rate. Instead, the taxable loss increases the net operating loss carryforwards and will be subject to the lower 21% federal tax rate in future periods.

 

As of March 31, 2019, the Company had federal and state research credit carryforwards of $163.5 million and $146.3 million, respectively, which begin to expire in fiscal year 2026 and fiscal year 2020, respectively. As of March 31, 2019, the Company also had foreign tax credit carryforwards of approximately $1.6 million, which begin to expire in fiscal year 2021. As of March 31, 2019, the Company had federal and state net operating loss carryforwards of $761.5 million and $585.1 million, respectively, which begin to expire in fiscal year 2021 and fiscal year 2020, respectively. The Tax Reform repealed the alternative minimum tax (AMT) for tax years beginning January 1, 2018, and provides that existing AMT credit carryovers are refundable beginning in calendar year 2018. The Company has an insignificant amount of AMT credit carryovers that are expected to be fully refunded by fiscal year 2022.

In accordance with ASU 2016-09, which the Company adopted during the first quarter of fiscal year 2018, the Company recorded a cumulative effect adjustment as of the beginning of the first quarter of fiscal year 2018 to increase retained earnings by $58.7 million with a corresponding increase to deferred tax assets to recognize net operating loss carryforwards attributable to excess tax benefits on share-based compensation that had not been previously recognized. On a prospective basis the Company recognizes excess tax benefits or deficiencies on vesting or settlement of awards as discrete items within income tax benefit or provision within net income (loss) and the related cash flows classified within operating activities.

In accordance with the authoritative guidance for income taxes (ASC 740), net deferred tax assets are reduced by a valuation allowance if, based on all the available evidence, it is more likely than not that some or all of the deferred tax assets will not be realized. Future realization of existing deferred tax assets ultimately depends on future profitability and the existence of sufficient taxable income of appropriate character (for example, ordinary income versus capital gains) within the carryforward period available under tax law. In the event that the Company’s estimate of taxable income is less than that required to utilize the full amount of any deferred tax asset, a valuation allowance is established, which would cause a decrease to income in the period such determination is made. A valuation allowance of $33.5 million at March 31, 2019 and $29.0 million at March 31, 2018 has been established relating to state and foreign net operating loss carryforwards, state R&D tax credit carryforwards, and foreign tax credit carryforwards that, based on management’s estimate of future taxable income attributable to such jurisdictions and generation of additional research credits, are considered more likely than not to expire unused.

 

The following table summarizes the activity related to the Company’s unrecognized tax benefits:

 

 

 

As of

 

 

 

March 31,

2019

 

 

March 31,

2018

 

 

March 31,

2017

 

 

 

(In thousands)

 

Balance, beginning of fiscal year

 

$

55,474

 

 

$

49,066

 

 

$

45,080

 

Decrease related to prior year tax positions

 

 

(1,183

)

 

 

(155

)

 

 

(421

)

Increases related to current year tax positions

 

 

13,865

 

 

 

6,563

 

 

 

4,407

 

Balance, end of fiscal year

 

$

68,156

 

 

$

55,474

 

 

$

49,066

 

 

Of the total unrecognized tax benefits at March 31, 2019, $61.2 million would reduce the Company’s annual effective tax rate if recognized, subject to valuation allowance consideration.

In the next 12 months it is reasonably possible that the amount of unrecognized tax benefits will not change significantly.

The Company is subject to periodic audits by domestic and foreign tax authorities. By statute, the Company’s U.S. federal income tax returns are subject to examination by the Internal Revenue Service (IRS) for fiscal years 2016 through 2018. Additionally, tax credit carryovers that were generated in prior years and utilized in these years may also be subject to examination by the IRS. With few exceptions, fiscal years 2015 to 2018 remain open to examination by state and foreign taxing jurisdictions. The Company believes that it has appropriate support for the income tax positions taken on its tax returns and its accruals for tax liabilities are adequate for all open years based on an assessment of many factors, including past experience and interpretations. The Company’s policy is to recognize interest expense and penalties related to income tax matters as a component of income tax expense. There were no accrued interest or penalties associated with uncertain tax positions as of March 31, 2019 and 2018.

U.S. Tax Reform

On December 22, 2017, the Tax Reform was enacted into law. Among other matters, the Tax Reform lowered the corporate federal income tax rate from 35% to 21%, effective January 1, 2018, and transitioned U.S. international taxation from a worldwide tax system to a modified territorial tax system, including a one-time transition tax on accumulated foreign earnings, and created new taxes on certain foreign earnings.

The Company re-measured its deferred tax balances as of December 22, 2017 to reflect the 21% reduced tax rate and recognized an income tax expense of $5.3 million for the fiscal year ended March 31, 2018. The one-time transition tax had no impact to the Company’s income tax provision.

The Securities and Exchange Commission issued rules under SAB 118 that allowed for a measurement period of up to one year after the enactment date of the Tax Reform to finalize the recording of the related enactment-date tax impacts. The Company finalized its accounting for the related enactment-date tax impacts during fiscal year 2019 with no adjustments to the provisional estimate recorded at December 31, 2017. The Company has accounted for the fiscal year 2019 impacts of the Tax Reform in its benefit from (provision for) income taxes in accordance with its interpretation of the Tax Reform and available guidance. However, additional Treasury regulations and other interpretive guidance are expected. The impact of any additional guidance will be recorded in the subsequent periods in which the additional guidance is released.