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Income Taxes
6 Months Ended
Mar. 31, 2019
Income Tax Disclosure [Abstract]  
Income Taxes
Note 6 — Income Taxes

Results for the three and six months ended March 31, 2018, reflect the impacts of two significant tax law changes in the U.S. and in France including remeasurement adjustments to deferred income tax assets and liabilities in the U.S. and France. The following sections describe these tax law changes.

TCJA

On December 22, 2017, the TCJA was enacted into law. Among the significant changes resulting from the law, the TCJA reduced the U.S. federal income tax rate from 35% to 21%, effective January 1, 2018, created a territorial tax system with a one-time mandatory “toll tax” on previously un-repatriated foreign earnings, and allowed for immediate capital expensing of certain qualified property. It also applied restrictions on the deductibility of interest expense, eliminated bonus depreciation for regulated utilities and certain FERC-regulated property beginning in Fiscal 2019, and applied a broader application of compensation limitations.
In accordance with GAAP as determined by ASC 740 we are required to record the effects of tax law changes in the period enacted. As further discussed below, our results for the three and six months ended March 31, 2018, contained provisional estimates of the impact of the TCJA. These amounts were considered provisional because they used estimates for which tax returns had not yet been filed and because estimated amounts could have been impacted by future regulatory and accounting guidance if and when issued. We adjusted provisional amounts as further information became available and as we refined our calculations. As permitted by SEC Staff Accounting Bulletin No. 118, these adjustments occurred during the reasonable “measurement period” defined as twelve months from the date of enactment. During the three months ended December 31, 2018, adjustments to provisional amounts recorded in prior periods were not material.
As a result of the enactment of the TCJA on December 22, 2017, during the three and six months ended March 31, 2018, we reduced our net deferred income tax liabilities by $5.0 and $388.8, respectively, due to the remeasuring of our existing federal deferred income tax assets and liabilities as of the date of the enactment of the TCJA, and as a result of adjusting our original provisional amounts during the quarter ended March 31, 2018. Because current law requires that excess deferred income taxes associated with UGI Utilities’ regulated utility plant assets are to be amortized no more rapidly than over the remaining lives of the assets that gave rise to the excess deferred taxes, UGI Utilities recorded a regulatory liability related to such excess deferred income taxes (see Note 8).
For the six months ended March 31, 2018, discrete deferred income tax adjustments reduced income tax expense by $171.3, which amount is net of $5.3 of adjustments recorded during the three months ended March 31, 2018 in accordance with the previously mentioned SEC Staff Accounting Bulletin No. 118. The $171.3 discrete deferred income tax adjustment for the six months ended March 31, 2018, was comprised of the following:
(1)a $180.3 reduction in net deferred tax liabilities in the U.S from the reduction of the U.S. tax rate;
(2)the establishment of $7.6 of valuation allowances related to deferred tax assets impacted by U.S. tax law changes; and
(3)a $1.4 “toll tax” on un-repatriated foreign earnings.

For the three and six months ended March 31, 2019 and 2018, we included the estimated impacts of the TCJA in determining our estimated annual effective income tax rates. We are subject to a 21.0% U.S. federal tax rate in Fiscal 2019. We were subject to a blended U.S. federal tax rate of 24.5% for Fiscal 2018 because our fiscal year contained the effective date of the rate change from 35% to 21% on January 1, 2018. As a result, our annual effective income tax rates used for the six months ended March 31, 2019 was based upon a federal income tax rate of 21.0% and our annual effective tax rate used for the six months ended March 31, 2018 was based upon a federal income tax rate of 24.5%. Our estimated annual effective tax rate was not impacted by any regulatory action taken by the PAPUC.
December 2017 French Finance Bills
In December 2017, the December 2017 French Finance Bills were approved. One impact of the December 2017 French Finance Bills was an increase in the Fiscal 2018 corporate income tax rate in France from 34.4% to 39.4%. The December 2017 French Finance Bills also include measures to reduce the corporate income tax rate to 25.8%, effective for fiscal years starting after January 1, 2022 (Fiscal 2023). As a result of the future corporate income tax rate reduction effective in Fiscal 2023, during the three months ended December 31, 2017, the Company reduced its net French deferred income tax liabilities and recognized an estimated deferred tax benefit of $17.3. During the three months ended March 31, 2018, this estimated deferred tax benefit was adjusted downward by $3.7 to $13.6. The estimated annual effective income tax rate used in determining income taxes for the six months ended March 31, 2018, reflected the impact of the single year Fiscal 2018 income tax rate as a result of the December 2017 French Finance Bills.