INCOME TAXES |
9 Months Ended |
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Sep. 29, 2018 | |
Income Tax Disclosure [Abstract] | |
INCOME TAXES | INCOME TAXES On December 22, 2017, the Tax Cuts and Jobs Act of 2017 (the “Act”) was signed into law revising the US corporate income tax. Changes included, but are not limited to, a corporate tax rate decrease from 35% to 21% effective for tax years beginning after December 31, 2017, the elimination of certain deductions and imposing a mandatory one-time tax on accumulated earnings of foreign subsidiaries. The primary impacts of the Act reflected in the Condensed Consolidated Financial Statements relate to the remeasurement of deferred tax assets and liabilities resulting from the change in the corporate tax rate; a one-time mandatory transition tax on undistributed earnings of foreign affiliates; and deferred taxes in connection with a change in the Company’s intent to permanently reinvest the historical undistributed earnings of its foreign affiliates. The Securities and Exchange Commission (the “SEC”) provided guidance that allows the Company to record provisional amounts if the accounting assessment is incomplete for impacts of the Act, with the requirement that the accounting be finalized in a period not to exceed one year from the date of enactment. The Company recorded a net $1.0 million provisional reduction in tax expense in the fourth quarter of 2017, the period in which the legislation was enacted. The provisional benefit recognized related to the remeasurement of certain deferred tax assets and liabilities based on the rates at which they are expected to reverse was $51.0 million. The provisional expense recognized related to the one-time tax on the mandatory deemed repatriation of foreign earnings was $40.0 million of which the Company will elect to pay over a period of eight years. During the three months ended September 29, 2018, the U.S. Department of Treasury released proposed rules affecting the computation of the Company’s 2017 federal income tax liability. As a result of this new guidance and additional analysis of the impacts of the Act, the Company revised its prior estimates and recorded $6.6 million of tax benefit related to the Act during the three months ended September 29, 2018. The Company continues to treat these amounts as provisional until the final regulations are issued or one year from the date of enactment has lapsed, whichever is earlier. The final impact may differ from this estimate, possibly materially, if the final regulations are issued prior to December 29, 2018. The Act also subjects US shareholders to tax on Global Intangible Low Taxed Income (“GILTI”) earned by certain foreign subsidiaries. The FASB Staff Q&A, Topic 740, No. 5, Accounting for GILTI, states than an entity can make an accounting policy election to either recognize deferred taxes for temporary basis differences expected to reverse as GILTI in future years or provide for the tax expense related to GILTI in the year the tax is incurred as a period expense only. Given the complexity of the GILTI provisions, the Company is still evaluating the effects of the GILTI provisions and has not yet determined an accounting policy. As of September 29, 2018, the Company has included GILTI related to current year earnings only in its estimated annual effective tax rate and has not provided additional GILTI on deferred items. The effective tax rate for the three months ended September 29, 2018 was 6.4% versus 21.7% for the three months ended September 30, 2017. The effective tax rate for the nine months ended September 29, 2018 was 17.3% versus 21.9% for the nine months ended September 30, 2017. The change in the effective tax rate for the three months ended September 29, 2018 was primarily driven by the impact of the Act and the mix of earnings. The change in the effective tax rate for the nine months ended September 29, 2018 was primarily driven by the impact of the Act and the mix of earnings. As of September 29, 2018 and December 30, 2017, the Company had approximately $5.7 million and $6.7 million, respectively, of unrecognized tax benefits, all of which would impact the effective income tax rate if recognized. Potential interest and penalties related to unrecognized tax benefits are recorded in income tax expense. With few exceptions, the Company is no longer subject to US Federal and state/local income tax examinations by tax authorities for years prior to 2013, and the Company is no longer subject to non-US income tax examinations by tax authorities for years prior to 2011. |