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INCOME TAXES
12 Months Ended
Mar. 31, 2015
INCOME TAXES  
INCOME TAXES

13. INCOME TAXES

        The domestic (Singapore) and foreign components of income from continuing operations before income taxes were comprised of the following:

                                                                                                                                                                                    

 

 

Fiscal Year Ended March 31,

 

 

 

2015

 

2014

 

2013

 

 

 

(In thousands)

 

Domestic

 

$

67,482 

 

$

314,639 

 

$

170,071 

 

Foreign

 

 

603,173 

 

 

85,815 

 

 

158,744 

 

​  

​  

​  

​  

​  

​  

Total

 

$

670,655 

 

$

400,454 

 

$

328,815 

 

​  

​  

​  

​  

​  

​  

​  

​  

​  

​  

​  

​  

​  

        The provision for income taxes from continuing operations consisted of the following:

                                                                                                                                                                                    

 

 

Fiscal Year Ended March 31,

 

 

 

2015

 

2014

 

2013

 

 

 

(In thousands)

 

Current:

 

 

 

 

 

 

 

 

 

 

Domestic

 

$

87

 

$

(681

)

$

680

 

Foreign

 

 

129,863

 

 

73,992

 

 

60,466

 

​  

​  

​  

​  

​  

​  

 

 

 

129,950

 

 

73,311

 

 

61,146

 

Deferred:

 

 

 

 

 

 

 

 

 

 

Domestic

 

 

(4,734

)

 

9

 

 

(1,187

)

Foreign

 

 

(55,362

)

 

(38,460

)

 

(33,646

)

​  

​  

​  

​  

​  

​  

 

 

 

(60,096

)

 

(38,451

)

 

(34,833

)

​  

​  

​  

​  

​  

​  

Provision for income taxes

 

$

69,854

 

$

34,860

 

$

26,313

 

​  

​  

​  

​  

​  

​  

​  

​  

​  

​  

​  

​  

​  

        The domestic statutory income tax rate was approximately 17.0% in fiscal years 2015, 2014 and 2013. The reconciliation of the income tax expense from continuing operations expected based on domestic statutory income tax rates to the expense for income taxes included in the consolidated statements of operations is as follows:

                                                                                                                                                                                    

 

 

Fiscal Year Ended March 31,

 

 

 

2015

 

2014

 

2013

 

 

 

(In thousands)

 

Income taxes based on domestic statutory rates

 

$

114,011

 

$

68,077

 

$

55,899

 

Effect of tax rate differential

 

 

(80,842

)

 

(68,654

)

 

(120,785

)

Intangible amortization

 

 

5,143

 

 

4,750

 

 

4,881

 

Change in liability for uncertain tax positions

 

 

29,729

 

 

(2,178

)

 

15,268

 

Change in valuation allowance

 

 

2,495

 

 

26,838

 

 

68,596

 

Other

 

 

(682

)

 

6,027

 

 

2,454

 

​  

​  

​  

​  

​  

​  

Provision for income taxes

 

$

69,854

 

$

34,860

 

$

26,313

 

​  

​  

​  

​  

​  

​  

​  

​  

​  

​  

​  

​  

​  

        A number of countries in which the Company is located allow for tax holidays or provide other tax incentives to attract and retain business. In general, these holidays were secured based on the nature, size and location of the Company's operations. The aggregate dollar effect on the Company's income resulting from tax holidays and tax incentives to attract and retain business for the fiscal years ended March 31, 2015, 2014 and 2013 was $9.8 million, $15.2 million and $22.6 million, respectively. The effect on basic earnings per share was $0.02 for both fiscal years ended March 31, 2015 and 2014, and $0.03 for the fiscal year ended March 31, 2013. The effect on diluted earnings per share was $0.02 for both fiscal years ended March 31, 2015 and 2014, and $0.03 for the fiscal year ended March 31, 2013. Unless extended or otherwise renegotiated, the Company's existing holidays will expire in the fiscal years ending March 31, 2016 through fiscal year 2022.

        Under its territorial tax system, Singapore generally does not tax foreign sourced income until repatriated to Singapore. The Company has included the effects of Singapore's territorial tax system in the rate differential line above. The tax effect of foreign income not repatriated to Singapore for the fiscal years 2014 and 2013 were $51.5 million and $26.7 million, respectively. Due to the lack of sufficient foreign source income, tax effect for the fiscal year 2015 was zero.

        The components of deferred income taxes are as follows:

                                                                                                                                                                                    

 

 

As of March 31,

 

 

 

2015

 

2014

 

 

 

(In thousands)

 

Deferred tax liabilities:

 

 

 

 

 

 

 

Fixed assets

 

$

(73,327

)

$

(76,524

)

Others

 

 

(44,603

)

 

(54,900

)

​  

​  

​  

​  

Total deferred tax liabilities

 

 

(117,930

)

 

(131,424

)

​  

​  

​  

​  

Deferred tax assets:

 

 

 

 

 

 

 

Fixed assets

 

 

80,370

 

 

80,801

 

Intangible assets

 

 

28,954

 

 

62,951

 

Deferred compensation

 

 

13,618

 

 

10,263

 

Inventory valuation

 

 

11,864

 

 

9,255

 

Provision for doubtful accounts

 

 

3,149

 

 

3,558

 

Net operating loss and other carryforwards

 

 

2,394,456

 

 

2,613,095

 

Others

 

 

264,781

 

 

201,906

 

​  

​  

​  

​  

 

 

 

2,797,192

 

 

2,981,829

 

Valuation allowances

 

 

(2,521,763

)

 

(2,749,040

)

​  

​  

​  

​  

Net deferred tax assets, net of valuation allowance

 

 

275,429

 

 

232,789

 

​  

​  

​  

​  

Net deferred tax asset

 

$

157,499

 

$

101,365

 

​  

​  

​  

​  

​  

​  

​  

​  

​  

The net deferred tax asset is classified as follows:

 

 

 

 

 

 

 

Current asset (classified as other current assets)

 

$

63,910

 

$

13,522

 

Long-term asset (classified as other assets)

 

 

211,519

 

 

219,267

 

Long-term liability (classified as other liabilities)

 

 

(117,930

)

 

(131,424

)

​  

​  

​  

​  

Total

 

$

157,499

 

$

101,365

 

​  

​  

​  

​  

​  

​  

​  

​  

​  

        Utilization of the Company's deferred tax assets is limited by the future earnings of the Company in the tax jurisdictions in which such deferred assets arose. As a result, management is uncertain as to when or whether these operations will generate sufficient profit to realize any benefit from the deferred tax assets. The valuation allowance provides a reserve against deferred tax assets that are not more likely than not to be realized by the Company. However, management has determined that it is more likely than not that the Company will realize certain of these benefits and, accordingly, has recognized a deferred tax asset from these benefits. The change in valuation allowance is net of certain increases and decreases to prior year losses and other carryforwards that have no current impact on the tax provision. Approximately $34.0 million of the valuation allowance relates to income tax benefits arising from the exercise of stock options, which if realized will be credited directly to shareholders' equity and will not be available to benefit the income tax provision in any future period.

        The Company has recorded deferred tax assets of approximately $2.4 billion related to tax losses and other carryforwards against which the Company has recorded a valuation allowance for all but $45.4 million of the deferred tax assets. These tax losses and other carryforwards, on a tax return basis, will expire at various dates as follows:

                                                                                                                                                                                    

Expiration dates of deferred tax assets related to operating losses and other carryforwards

 

 

 

(In thousands)

 

2016 - 2021

 

$

344,790 

 

2022 - 2027

 

 

939,453 

 

2028 and post

 

 

660,072 

 

Indefinite

 

 

482,527 

 

​  

​  

 

 

$

2,426,842 

 

​  

​  

​  

​  

​  

        The amount of deferred tax assets considered realizable, however, could be reduced or increased in the near-term if facts, including the amount of taxable income or the mix of taxable income between subsidiaries, differ from management's estimates.

        The Company does not provide for income taxes on approximately $800.0 million of undistributed earnings of its subsidiaries which are considered to be indefinitely reinvested outside of Singapore as management has plans for the use of such earnings to fund certain activities outside of Singapore. Determination of the amount of the unrecognized deferred tax liability on these undistributed earnings is not practicable. During the fiscal year 2015, we changed our intent with regard to the indefinite reinvestment of foreign earnings from certain of our Chinese subsidiaries which are scheduled to be de-registered or liquidated in the near future. As a result, we provided for applicable foreign withholding taxes on $145.9 million of undistributed foreign earnings for 2015 and prior years, and recorded a deferred tax liability of approximately $12.6 million.

        A reconciliation of the beginning and ending amount of unrecognized tax benefits is as follows:

                                                                                                                                                                                    

 

 

Fiscal Year Ended
March 31,

 

 

 

2015

 

2014

 

 

 

(In thousands)

 

Balance, beginning of fiscal year

 

$

243,864

 

$

230,018

 

Additions based on tax position related to the current year

 

 

27,048

 

 

16,823

 

Additions for tax positions of prior years

 

 

24,354

 

 

36,689

 

Reductions for tax positions of prior years

 

 

(16,388

)

 

(19,755

)

Reductions related to lapse of applicable statute of limitations

 

 

(11,891

)

 

(10,261

)

Settlements

 

 

(24,049

)

 

(8,964

)

Impact from foreign exchange rates fluctuation

 

 

(20,565

)

 

(686

)

​  

​  

​  

​  

Balance, end of fiscal year

 

$

222,373

 

$

243,864

 

​  

​  

​  

​  

​  

​  

​  

​  

​  

        The Company's unrecognized tax benefits are subject to change over the next twelve months primarily as a result of the expiration of certain statutes of limitations and as audits are settled. The Company believes it is reasonably possible that the total amount of unrecognized tax benefits could decrease by an estimated range of $25 million to $52 million within the next twelve months primarily due to potential settlements of various audits and the expiration of certain statutes of limitations.

        The Company and its subsidiaries file federal, state, and local income tax returns in multiple jurisdictions around the world. With few exceptions, the Company is no longer subject to income tax examinations by tax authorities for years before 2005.

        Of the $222.4 million of unrecognized tax benefits at March 31, 2015, $186.8 million will affect the annual effective tax rate if the benefits are eventually recognized. The amount that does not impact the effective tax rate relates to positions that would be settled with a tax loss carryforward previously subject to a valuation allowance.

        The Company recognizes interest and penalties accrued related to unrecognized tax benefits within the Company's tax expense. During the fiscal years ended March 31, 2015, 2014 and 2013, the Company recognized interest and penalties of approximately $2.5 million and $8.4 million and $5.1 million, respectively. The Company had approximately $17.0 million, $15.6 million and $11.9 million accrued for the payment of interest and penalties as of the fiscal years ended March 31, 2015, 2014 and 2013, respectively.