Income Taxes

12 Months Ended

Oct. 03, 2021

Income Tax Disclosure [Abstract]

Income Taxes

Income TaxesComponents of earnings before income taxes (in millions):

Fiscal Year Ended	Oct 3, 2021		Sep 27, 2020		Sep 29, 2019
United States	$	4,138.5	$	904.6	$	3,518.7
Foreign	1,218.4		259.8		947.5
Total earnings before income taxes	$	5,356.9	$	1,164.4	$	4,466.2

Provision/(benefit) for income taxes (in millions):

Fiscal Year Ended	Oct 3, 2021		Sep 27, 2020		Sep 29, 2019
Current taxes:
U.S. federal	$	681.8	$	49.9	$	1,414.3
U.S. state and local	190.0		36.9		447.8
Foreign	409.8		181.4		458.3
Total current taxes	1,281.6		268.2		2,320.4
Deferred taxes:
U.S. federal	10.4		(8.4)		(1,074.5)
U.S. state and local	(6.4)		(4.8)		(322.4)
Foreign	(129.0)		(15.3)		(51.9)
Total deferred taxes	(125.0)		(28.5)		(1,448.8)
Total income tax expense	$	1,156.6	$	239.7	$	871.6

Reconciliation of the statutory U.S. federal income tax rate with our effective income tax rate:

Fiscal Year Ended	Oct 3, 2021		Sep 27, 2020		Sep 29, 2019
Statutory rate	21.0	%	21.0	%	21.0	%
State income taxes, net of federal tax benefit	2.7		2.2		2.1
Foreign rate differential	0.5		(3.2)		(0.1)
Change in tax rates	(1.3)		(2.2)		—
Excess tax benefits of stock-based compensation	(0.9)		(4.2)		(2.1)
Foreign derived intangible income	(0.5)		(1.4)		(1.5)
Charitable contributions	(0.4)		(1.7)		—
Valuation allowances	0.2		10.0		—
Residual tax on foreign earnings	—		—		1.7
Tax impacts related to sale of certain operations	—		—		(1.3)
Other, net	0.3		0.1		(0.3)
Effective tax rate	21.6	%	20.6	%	19.5	%

As of October 3, 2021, in certain foreign subsidiaries in which we are partially indefinitely reinvested, the gross taxable temporary difference between the accounting basis and tax basis was approximately $1.8 billion for which there could be up to approximately $290 million of unrecognized tax liability.

Tax effect of temporary differences and carryforwards that comprise significant portions of deferred tax assets and liabilities (in millions):

	Oct 3, 2021		Sep 27, 2020
Deferred tax assets:
Operating lease liabilities	$	2,395.2	$	2,313.0
Stored value card liability and deferred revenue	1,679.4		1,678.6
Intangible assets and goodwill	317.7		248.6
Other	641.0		554.4
Total	$	5,033.3	$	4,794.6
Valuation allowance	(275.3)		(239.4)
Total deferred tax asset, net of valuation allowance	$	4,758.0	$	4,555.2
Deferred tax liabilities:
Operating lease, right-of-use assets	(2,296.5)		(2,191.8)
Property, plant and equipment	(451.2)		(463.3)
Other	(284.0)		(268.3)
Total	(3,031.7)		(2,923.4)
Net deferred tax asset (liability)	$	1,726.3	$	1,631.8
Reported as:
Deferred income tax assets	1,874.8		1,789.9
Deferred income tax liabilities (included in Other long-term liabilities)	(148.5)		(158.1)
Net deferred tax asset (liability)	$	1,726.3	$	1,631.8

The valuation allowances as of October 3, 2021 and September 27, 2020 were primarily related to net operating losses and other deferred tax assets of consolidated foreign subsidiaries.

As of October 3, 2021, we had federal net operating loss carryforwards of $70.8 million which have an indefinite carryforward period, state net operating loss carryforwards of $109.7 million which will begin to expire in fiscal 2024, federal tax credit carryforwards of $21.8 million which will begin to expire in fiscal 2030, state tax credit carryforwards of $1.2 million which will begin to expire in fiscal 2024 and foreign net operating loss carryforwards of $327.9 million, of which $118.8 million have an indefinite carryforward period and the remainder expire at various dates starting from fiscal 2022.

Uncertain Tax Positions

As of October 3, 2021, we had $82.6 million of gross unrecognized tax benefits of which $62.8 million, if recognized, would affect our effective tax rate. We recognized a benefit of $4.6 million, an expense of $3.0 million and a benefit of $2.8 million of interest and penalties in income tax expense, prior to the benefit of the federal tax deduction, for fiscal 2021, 2020 and 2019, respectively. As of October 3, 2021 and September 27, 2020, we had accrued interest and penalties of $7.1 million and $13.0 million, respectively, within our consolidated balance sheets.

The following table summarizes the activity related to our unrecognized tax benefits (in millions):

	Oct 3, 2021		Sep 27, 2020		Sep 29, 2019
Beginning balance	$	123.7	$	132.1	$	224.6
Increase related to prior year tax positions	4.8		11.1		3.8
Decrease related to prior year tax positions	(11.9)		(0.5)		(75.3)
Increase related to current year tax positions	8.9		9.8		18.5
Decreases related to settlements with taxing authorities	(4.4)		—		(16.4)
Decrease related to lapsing of statute of limitations	(38.5)		(28.8)		(23.1)
Ending balance	$	82.6	$	123.7	$	132.1

We are currently under examination, or may be subject to examination, by various U.S. federal, state, local and foreign tax jurisdictions for fiscal 2014 through 2020. We are no longer subject to U.S. federal examination for years prior to fiscal 2018, U.S. state and local examinations for years prior to fiscal 2014 or examination in any material international markets prior to 2015.

We do not expect a significant amount of Company's gross unrecognized tax benefits to be recognized by the end of fiscal 2022 for reasons such as a lapse of the statute of limitations or resolution of examinations with tax authorities.