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Income Taxes
12 Months Ended
Aug. 31, 2015
Income Taxes [Abstract]  
Income Taxes

 

 

15.INCOME TAXES

 

Our provision for income taxes consisted of the following (in thousands):

 

 

 

 

 

 

 

 

 

 

 

 

 

 

YEAR ENDED

 

 

 

 

 

 

AUGUST 31,

 

2015 

 

2014 

 

2013 

Current:

 

 

 

 

 

 

Federal

$

220 

$

(237)

$

1,251 

State

 

208 

 

146 

 

273 

Foreign

 

2,691 

 

2,557 

 

3,256 

 

 

3,119 

 

2,466 

 

4,780 

 

 

 

 

 

 

 

Deferred:

 

 

 

 

 

 

Federal

 

3,239 

 

1,217 

 

864 

State

 

138 

 

277 

 

(414)

Foreign

 

(200)

 

(268)

 

(151)

 

 

3,177 

 

1,226 

 

299 

 

$

6,296 

$

3,692 

$

5,079 

 

The allocation of the total income tax provision is as follows (in thousands):

 

 

 

 

 

 

 

 

 

 

 

 

 

 

YEAR ENDED

 

 

 

 

 

 

AUGUST 31,

 

2015 

 

2014 

 

2013 

Net income

$

6,296 

$

3,692 

$

5,079 

Other comprehensive income

 

(52)

 

24 

 

(260)

 

$

6,244 

$

3,716 

$

4,819 

 

Income before income taxes consisted of the following (in thousands):

 

 

 

 

 

 

 

 

 

 

 

 

 

 

YEAR ENDED

 

 

 

 

 

 

AUGUST 31,

 

2015 

 

2014 

 

2013 

United States

$

15,073 

$

19,256 

$

14,939 

Foreign

 

2,339 

 

2,503 

 

4,459 

 

$

17,412 

$

21,759 

$

19,398 

 

The differences between income taxes at the statutory federal income tax rate and the consolidated income tax rate reported in our consolidated income statements were as follows:

 

 

 

 

 

YEAR ENDED 

AUGUST 31,

2015 
2014 
2013 

Federal statutory income tax rate

35.0% 
35.0% 
35.0% 

State income taxes, net of federal effect

2.3 
1.9 
1.6 

Foreign jurisdictions tax differential

1.2 
(0.4)
1.0 

Tax differential on income subject to both U.S. and foreign taxes

0.5 
0.5 
(3.3)

Effect of claiming foreign tax credits instead of deductions for prior years

(3.2)
(19.3)
(12.2)

Uncertain tax positions

(0.9)
(2.6)
1.8 

Management stock loan interest and non-deductible expenses

 

-

 

-

1.3 

Non-deductible executive compensation

0.2 
0.9 
0.9 

Non-deductible meals and entertainment

1.1 
0.8 
0.8 

Other

-

0.2 
(0.7)

 

36.2% 
17.0% 
26.2% 

 

In prior fiscal years, we elected to take deductions on our U.S. federal income tax returns for foreign income taxes paid, rather than claiming foreign tax credits.  During those years we either generated or used net operating loss carryforwards and were therefore unable to utilize foreign tax credits.  In fiscal 2011 we began claiming foreign tax credits on our U.S. federal income tax returns.  Although we could not utilize the credits we claimed for fiscal 2012 and fiscal 2011 in those respective years, we concluded it was more likely than not that these foreign tax credits will be utilized in the future.

 

Since August 31, 2012, we have no remaining U.S. federal net operating loss carryforwards.  Additionally, overall U.S. taxable income and foreign source income for fiscal 2014 and 2013 were sufficient to utilize all of the foreign tax credits generated during those fiscal years, plus additional credits generated in prior years.  Accordingly, we amended our U.S. federal income tax returns from fiscal 2003 through fiscal 2010 to claim foreign tax credits instead of foreign tax deductions.  The net tax benefit resulting from claiming these additional foreign tax credits, which was recorded in the period the decision was made to amend the related returns, totaled $4.2 million in fiscal 2014 and $2.4 million in fiscal 2013.  In fiscal 2015 we finalized the calculations of the impact of amending previously filed federal income tax returns to realize foreign tax credits previously treated as expired under the tax positions taken in the original returns.  The income tax benefit recognized from these foreign tax credits totaled $0.6 million in fiscal 2015.

 

During the fiscal year ended August 31, 2013, we accrued taxable interest income on outstanding management common stock loans (Note 19).  Consistent with the accounting treatment for these loans, we did not recognize interest income, thus resulting in a permanent book versus tax difference.  We also recognized expenses during fiscal 2013 in connection with the resolution of the management stock loans, which were not deductible for income tax purposes.

 

We recognized tax benefits from deductions for share-based compensation in excess of the corresponding expense recorded for financial statement purposes.  Instead of reducing our income tax expense for these benefits, we recorded $0.1 million, $2.5 million, and $0.9 million to additional paid-in capital in the fiscal years ending August 31, 2015, 2014, and 2013.

 

The significant components of our deferred tax assets and liabilities were comprised of the following (in thousands):

 

 

 

 

 

 

 

 

 

 

AUGUST 31,

 

2015 

 

2014 

Deferred income tax assets:

 

 

 

 

Sale and financing of corporate

 

 

 

 

headquarters

$

9,531 

$

9,951 

Foreign income tax credit

 

 

 

 

carryforward

 

5,106 

 

8,025 

Share-based compensation

 

1,671 

 

1,258 

Inventory and bad debt reserves

 

1,025 

 

847 

Bonus and other accruals

 

934 

 

994 

Unearned revenue

 

328 

 

2,253 

Other

 

810 

 

671 

Total deferred income tax assets

 

19,405 

 

23,999 

Less: valuation allowance

 

 -

 

 -

Net deferred income tax assets

 

19,405 

 

23,999 

 

 

 

 

 

Deferred income tax liabilities:

 

 

 

 

Intangibles step-ups – indefinite lived

 

(8,515)

 

(8,475)

Intangibles step-ups – definite lived

 

(6,552)

 

(7,075)

Property and equipment depreciation

 

(3,139)

 

(3,854)

Intangible asset impairment and

 

 

 

 

amortization

 

(5,001)

 

(5,157)

Unremitted earnings of foreign

 

 

 

 

subsidiaries

 

(546)

 

(503)

Other

 

(77)

 

(80)

Total deferred income tax liabilities

 

(23,830)

 

(25,144)

Net deferred income taxes

$

(4,425)

$

(1,145)

 

Deferred income tax amounts are recorded as follows in our consolidated balance sheets (in thousands):

 

 

 

 

 

 

 

 

 

 

AUGUST 31,

 

2015 

 

2014 

Current assets

$

2,479 

$

4,340 

Long-term assets

 

194 

 

90 

Long-term liabilities

 

(7,098)

 

(5,575)

Net deferred income tax liability

$

(4,425)

$

(1,145)

 

As of August 31, 2015 we have utilized all of our U.S. federal net operating loss carryforwards.  The Company still has U.S. state net operating loss carryforwards generated in various jurisdictions that expire primarily between September 1, 2015 and August 31, 2029.

 

Our U.S. foreign income tax credit carryforwards were comprised of the following at August 31, 2015 (in thousands):

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Credit Generated in

 

 

 

 

 

Credits Used

 

Credits Used

 

Credits

Fiscal Year Ended

 

Credit Expires

 

Credits

 

in Prior

 

in Fiscal

 

Carried

August 31,

 

August 31,

 

Generated

 

Years

 

2015

 

Forward

2008

 

2018

$

1,444 

$

(1,444)

$

 -

$

 -

2009

 

2019

 

2,006 

 

(1,041)

 

(965)

 

 -

2010

 

2020

 

2,907 

 

 -

 

(1,247)

 

1,660 

2011

 

2021

 

3,446 

 

 -

 

 -

 

3,446 

2012

 

2022

 

2,563 

 

(2,563)

 

 -

 

 -

2013

 

2023

 

2,815 

 

(2,815)

 

 -

 

 -

2014

 

2024

 

1,378 

 

(1,378)

 

 -

 

 -

2015

 

2025

 

1,441 

 

 -

 

(1,441)

 

 -

 

 

 

$

18,000 

$

(9,241)

$

(3,653)

$

5,106 

 

We amended our U.S. federal income tax returns from fiscal 2003 through fiscal 2010 to claim foreign tax credits instead of the foreign tax deductions that were previously claimed.  The additional taxable income from claiming these foreign tax credits results in the complete utilization of our remaining net operating loss carryforwards in fiscal 2012, as well as the ability to utilize all of the foreign tax credit generated in fiscal 2012.

 

We have determined that projected future taxable income is adequate to allow for realization of all deferred tax assets.  We considered sources of taxable income, including future reversals of taxable temporary differences, future taxable income exclusive of reversing temporary differences and carryforwards, and reasonable, practical tax-planning strategies to generate additional taxable income.  Based on the factors described above, we concluded that realization of all our deferred tax assets is more likely than not at August 31, 2015.

 

A reconciliation of the beginning and ending amount of gross unrecognized tax benefits is as follows (in thousands):

 

 

 

 

 

 

 

 

 

 

 

 

 

 

YEAR ENDED

 

 

 

 

 

 

AUGUST 31,

 

2015 

 

2014 

 

2013 

Beginning balance

$

3,491 

$

4,129 

$

4,212 

Additions based on tax positions

 

 

 

 

 

 

related to the current year

 

244 

 

157 

 

720 

Additions for tax positions in

 

 

 

 

 

 

prior years

 

144 

 

60 

 

69 

Reductions for tax positions of prior

 

 

 

 

 

 

years resulting from the lapse of

 

 

 

 

 

 

applicable statute of limitations

 

(339)

 

(663)

 

(74)

Other reductions for tax positions of

 

 

 

 

 

 

prior years

 

(425)

 

(192)

 

(798)

Ending balance

$

3,115 

$

3,491 

$

4,129 

 

The total amount of unrecognized tax benefits that, if recognized, would affect the effective tax rate is $2.2 million at August 31, 2015 and $2.5 million at August 31, 2014.  Included in the ending balance of gross unrecognized tax benefits at August 31, 2015 is $2.8 million related to individual states’ net operating loss carryforwards.  Interest and penalties related to uncertain tax positions are recognized as components of income tax expense.  The net accruals and reversals of interest and penalties increased income tax expense by an insignificant amount in fiscal 2015 and fiscal 2014, and increased income tax expense by $0.1 million in fiscal 2013.  The balance of interest and penalties included on our consolidated balance sheets at August 31, 2015 and 2014 was $0.3 million each year.  We do not expect a material change in our unrecognized tax benefits over the next 12 months.

 

We file United States federal income tax returns as well as income tax returns in various states and foreign jurisdictions.  The tax years that remain subject to examinations for our major tax jurisdictions are shown below. 

 

 2008-2015 

Canada

 2008-2015

Australia

 2010-2015 

Japan, United Kingdom

 2011-2015 

United States – state and local income tax

 2012-2015 

United States – federal income tax