INCOME TAXES

The income tax provision consists of the following (amounts in thousands):



	Year Ended March 31,
	2015			2014			2013
Pretax Income:
U.S.	(944		)	28,245			(82,163		)
Foreign	346,851			404,109			234,340
	$	345,907		$	432,354		$	152,177
Current expense:
U.S. Federal	$	(3,185	)	$	992		$	33,856
State	(24		)	64			2,350
Foreign	16,602			30,697			16,950
Total current	$	13,393		31,753			53,156
Deferred expense (benefit):
U.S. Federal	$	(22,641	)	14,445			(16,004		)
State	(1,562		)	929			(1,111		)
Foreign	(8,608		)	(10,054		)	(11,253		)
Total deferred	(32,811		)	5,320			(28,368		)
	$	(19,418	)	$	37,073		$	24,788

The tax benefit associated with the Company's equity incentive plans reduced taxes currently payable by $1.2 million, $1.4 million and $0.3 million for the years ended March 31, 2015, 2014 and 2013, respectively. These amounts were credited to additional paid-in capital in each of these fiscal years.

The provision for income taxes differs from the amount computed by applying the statutory federal tax rate to income before income taxes. The sources and tax effects of the differences in the total income tax provision are as follows (amounts in thousands):



	Year Ended March 31,
	2015			2014			2013
Computed expected income tax provision	$	121,067		$	151,324		$	53,262
State income taxes, net of federal benefits	(20		)	686			(2,054		)
Research and development tax credits - current year	(9,703		)	(4,875		)	(8,263		)
Research and development tax credits - prior years	(1,789		)	1,600			(3,347		)
Foreign income taxed at lower than the federal rate	(106,939		)	(116,003		)	(61,377		)
Increases related to current and prior year tax positions	26,189			16,809			44,661
Decreases related to prior year tax positions ⁽¹⁾	(40,609		)	(14,581		)	(7,154		)
Withholding taxes	5,218			6,212			7,267
Change in valuation allowance	(14,286		)	—			—
Other	1,454			(4,099		)	1,793
	$	(19,418	)	$	37,073		$	24,788

⁽¹⁾ The release of prior year tax positions during fiscal 2015 increased each of the current year basic and diluted net income per common share by $0.16 and $0.15, respectively. The release of prior year tax positions during fiscal 2014 increased each of the current year basic and diluted net income per common share by $0.07. The release of prior year tax positions during fiscal 2013 increased the current year basic and diluted net income per common share by $0.04 and $0.03, respectively.

The foreign tax rate differential benefit primarily relates to the Company's operations in Thailand, Cayman and Ireland. The Company's Thailand manufacturing operations are currently subject to numerous tax holidays granted to the Company based on its investment in property, plant and equipment in Thailand. The Company's tax holiday periods in Thailand expire at various times in the future, however, the Company actively seeks to obtain new tax holidays. The Company does not expect the future expiration of any of its tax holiday periods in Thailand to have a material impact on its effective tax rate. The aggregate dollar benefits derived from these tax holidays approximated $12.4 million, $16.8 million and $12.0 million in fiscal 2015, 2014 and 2013, respectively.

No U.S. income taxes have been provided on substantially all of the filing basis undistributed foreign earnings and profits of approximately $2.8 billion as of March 31, 2015 since the Company has the ability and intent to permanently reinvest these amounts. If such earnings were repatriated, additional tax expense may result, although the calculation of such additional taxes is not practicable.

During the year ended March 31, 2015, the Company settled an IRS examination of SMSC for fiscal years 2011 and 2010. In addition, the Company benefited from the expiration of the statute of limitations and other releases related to previously accrued tax reserves. The total tax benefit associated with these items resulted in a reduction of income tax provision of approximately $33.1 million and a decrease in the effective tax rate of 9.6%.

The tax effects of temporary differences that give rise to significant portions of the deferred tax assets and deferred tax liabilities are as follows (amounts in thousands):



	March 31,
	2015			2014
Deferred tax assets:
Deferred intercompany profit	$	10,865		$	9,623
Deferred income on shipments to distributors	34,493			28,596
Inventory valuation	9,605			6,072
Net operating loss carryforward	105,756			110,598
Capital loss carryforward	4,582			—
Share-based compensation	26,780			24,494
Income tax credits	115,893			124,395
Accrued expenses and other	671			28,227
Gross deferred tax assets	308,645			332,005
Valuation allowances	(116,482		)	(93,811		)
Deferred tax assets, net of valuation allowances	192,163			238,194
Deferred tax liabilities:
Property, plant and equipment, principally due to differences in depreciation	2,236			(1,942		)
Convertible debentures	(493,897		)	(530,338		)
Other	(10,649		)	(13,740		)
Deferred tax liabilities	(502,310		)	(546,020		)
Net deferred tax liability	$	(310,147	)	$	(307,826	)

Reported as:
Current deferred tax assets	$	71,045		$	67,490
Non-current deferred tax liability	(381,192		)	(375,316		)
Net deferred tax liability	$	(310,147	)	$	(307,826	)

In addition to the deferred tax assets listed above, the Company has unrecorded tax benefits of $38.6 million attributable to the difference between the amount of the financial statement expense and the allowable tax deduction associated with share-based compensation. As a result of net operating loss (NOL) carryforwards, the Company was not able to recognize the excess tax benefits of share-based compensation deductions because the deductions did not reduce income tax payable. Although not recognized for financial reporting purposes, this unrecorded tax benefit is available to reduce future income and is incorporated into the disclosed amounts of the Company's federal and state NOL carryforwards, discussed below. If subsequently realized, the benefit will be recorded to contributed capital.

In assessing whether it is more likely than not that deferred tax assets will be realized, the Company considers all available evidence, both positive and negative, including its recent cumulative earnings experience and expectations of future available taxable income of the appropriate character by taxing jurisdiction, tax attribute carryback and carryforward periods available to them for tax reporting purposes, and prudent and feasible tax planning strategies.

The Company had federal, state and foreign NOL carryforwards with an estimated tax effect of $162.9 million available at March 31, 2015. The federal and state NOL carryforwards expire at various times between 2016 and 2035. The Company believes that it is more likely than not that the benefit from certain foreign and state NOL carryforwards will not be realized. In recognition of this risk, at March 31, 2015, the Company has provided a valuation allowance of $52.6 million. The Company also has state tax credits with an estimated tax effect of $59.1 million available at March 31, 2015. These state tax credits expire at various times between 2016 and 2035. The Company believes that it is more likely than not that the full benefit from these state tax credits will not be realized, and therefore has provided a valuation allowance of $34.4 million. The Company has capital loss carryforwards with an estimated tax effect of $4.6 million available at March 31, 2015. These capital loss carryforwards expire in 2020. The Company believes that it is more likely than not that the full benefit from these capital losses will not be realized, and therefore has provided a valuation allowance of $4.6 million. The Company had U.S foreign tax

credits with an estimated tax effect of $23.1 million that expire at various times between 2016 and 2025. The Company believes it is more likely than not that the benefit from these credits will not be fully realized and has provided a valuation allowance of $23.0 million. At March 31, 2015, the Company had credits for increasing research activity in the amount of $57.4 million that expire at various times between 2022 and 2035. In addition, the Company had $3.7 million of alternative minimum tax credits that do not expire.

On September 13, 2013, the IRS and the Treasury Department released final regulations under Section 162(a) and 263(a) on the deduction and capitalization of expenditures related to tangible property. The new regulations apply to tax years beginning on or after January 1, 2014. The Company believes that no material impact will result from these new regulations (specifically given the Company’s NOL position), but the Company is in the process of evaluating the full impact of these changes.

During the year ended March 31, 2015, the Tax Increase Prevention Act of 2014 was signed into law which extended certain business tax provisions through December 31, 2014, including IRC section 954(c)(6) dealing with the application of Subpart F to certain inter-company payments among controlled foreign corporations. The expiration of section 954(c)(6) and the other expired provisions could have a material impact on the Company's consolidated results of operations subsequent to the year ended March 31, 2015.

The Company recognizes interest and penalties related to unrecognized tax benefits through income tax expense. The Company is subject to income taxes in the U.S. and numerous foreign jurisdictions. The Company files U.S. federal, U.S. state, and foreign income tax returns. For U.S. federal, and in general for U.S. state tax returns, the fiscal 2011 and later tax years remain open for examination by tax authorities. The U.S. Internal Revenue Service (IRS) is currently auditing Microchip's 2011 and 2012 tax years. For foreign tax returns, the Company is generally no longer subject to income tax examinations for years prior to fiscal 2007.

Significant judgment is required in evaluating the Company's uncertain tax positions and determining its provision for income taxes. Although the Company believes that it has appropriately reserved for its uncertain tax positions, no assurance can be given that the final tax outcome of these matters will not be different than expectations. The Company will adjust these reserves in light of changing facts and circumstances, such as the closing of a tax audit, the refinement of an estimate, the closing of a statutory audit period or changes in applicable tax law. To the extent that the final tax outcome of these matters is different than the amounts recorded, such differences could impact the provision for income taxes in the period in which such determination is made. The provision for income taxes includes the impact of reserve provisions and changes to the reserves that are considered appropriate, as well as related net interest.

The Company recognizes liabilities for anticipated tax audit issues in the U.S. and other domestic and international tax jurisdictions based on its estimate of whether, and the extent to which, additional tax payments are more likely than not. The Company believes that it has appropriate support for the income tax positions taken and to be taken on its tax returns and that its accruals for tax liabilities are adequate for all open years based on an assessment of many factors including past experience and interpretations of tax law applied to the facts of each matter.

The Company believes it maintains appropriate reserves to offset any potential income tax liabilities that may arise upon final resolution of matters for open tax years. If such reserve amounts ultimately prove to be unnecessary, the resulting reversal of such reserves could result in tax benefits being recorded in the period the reserves are no longer deemed necessary. If such amounts prove to be less than an ultimate assessment, a future charge to expense would be recorded in the period in which the assessment is determined. Although the timing of the resolution and/or closure of audits is highly uncertain, the Company does not believe that it is reasonably possible that the unrecognized tax benefits would materially change in the next 12 months.

The following table summarizes the activity related to the Company's gross unrecognized tax benefits from April 1, 2012 to March 31, 2015 (amounts in thousands):



	Year Ended March 31,
	2015			2014			2013
Beginning balance	$	149,878		$	152,845		$	70,490
Increases related to acquisitions	8,381			341			45,624
Decreases related to settlements with tax authorities	(20,197		)	(15,016		)	—
Decreases related to statute of limitation expirations	(9,031		)	(4,069		)	(5,751		)
Increases related to current year tax positions	23,179			14,669			42,328
Increases related to prior year tax positions	18,444			1,108			154
Ending balance	$	170,654		$	149,878		$	152,845

As of March 31, 2015, the Company had accrued approximately $0.7 million related to the potential payment of interest on the Company's uncertain tax positions. As of March 31, 2014, the Company had accrued approximately $0.3 million related to the potential payment of interest on the Company's uncertain tax positions. Interest was included in the provision for income taxes. The Company has accrued for approximately $27.6 million and $29.7 million in penalties related to its uncertain tax positions related to its international locations as of March 31, 2015 and March 31, 2014, respectively. Interest and penalties charged or (credited) to operations during the years ended March 31, 2015, 2014 and 2013 related to the Company's uncertain tax positions were $(1.8) million, $0.2 million and $0.8 million, respectively. The increase related to prior year tax positions for March 31, 2015 related primarily to a balance sheet reclassification from a valuation allowance to a reserve in the amount of $15.7 million.