XML 30 R19.htm IDEA: XBRL DOCUMENT v3.8.0.1
Income Taxes
9 Months Ended
Mar. 31, 2018
Income Tax Disclosure [Abstract]  
Income Taxes
Note 12. Income Taxes
The Company recorded income tax expense of $1.1 million and $2.2 million for the three and nine months ended March 31, 2018 respectively. The Company recorded an income tax expense of $4.3 million and $15.8 million for the three and nine months ended April 1, 2017, respectively. 
The income tax expense for the three and nine months ended March 31, 2018 and April 1, 2017 primarily relates to income tax in certain foreign and state jurisdictions based on the Company’s forecasted pre-tax income or loss for the respective fiscal year. For the three and nine months ended March 31, 2018, this foreign and state tax is offset by a tax benefit of $4.0 million and $7.1 million, respectively, which was recorded in the Company’s income tax provision related to the income tax intraperiod allocation rules in relation to other comprehensive income. In accordance with authoritative guidance, this benefit may reverse during the fiscal year. Additionally, for the nine months ended March 31, 2018, the tax provision includes a benefit of $6.5 million resulting from the passage of the U.S. Tax Cuts and Jobs Act (“the Act”), the impacts of which are detailed below.
On December 22, 2017, the U.S. Tax Cuts and Jobs Act was enacted. Income tax effects resulting from changes in tax laws are accounted for by the Company in accordance with the authoritative guidance, which requires that these tax effects be recognized in the period in which the law is enacted, and the effects are recorded as a component of the provision for income taxes from continuing operations. The law has significantly changed the way the U.S. taxes corporations. The Act repealed the alternative minimum tax (“AMT”) for corporations and provided that the existing AMT credit carryforwards would be refunded in 2022 if not utilized. As a result, the Company recognized a benefit of $4.5 million for the nine months ended March 31, 2018 for the release of the valuation allowance previously maintained against the AMT credit deferred tax asset. In addition, under the Act, the Company’s current year net operating losses and any future net operating losses can now be carried forward indefinitely. As a result, the Company’s deferred tax liability associated with indefinite-lived intangible assets may now offset these indefinite-lived deferred tax assets, resulting in a benefit of $2.0 million for the nine months ended March 31, 2018 due to release of valuation allowance.
The Act imposed a deemed repatriation of the Company’s foreign subsidiaries’ post-1986 earnings and profits (“E&P”) which had previously been deferred from US income tax. The Company has made a provisional estimate of this deemed repatriation of E&P and has determined that there is no current period expense or liability due to the Company having sufficient estimated losses for the fiscal year to offset the income associated with the deemed repatriation. As previously noted, the impact of the deemed repatriation is a provisional estimate. The Company has not yet completed the calculation of the total post-1986 foreign E&P for all foreign subsidiaries. Further, this transition tax is based in part on the amount of those earnings held in cash and other specified assets. This amount may change when the Company finalizes the calculation of post-1986 foreign E&P previously deferred from U.S. federal taxation and finalizes the amounts held in cash or other specified assets. In addition, further interpretations from U.S. federal and state governments and regulatory organizations may change the provisional estimate or the accounting treatment of the provisional estimate.
The Act reduces the U.S. federal corporate tax rate from 35% to 21% as of January 1, 2018. The Company has not made sufficient progress on remeasuring its deferred tax assets and liabilities to determine a reasonable estimate at this time. However, the Company expects that there will be an equal and offsetting reduction in the valuation allowance such that there should be no impact to its provision for income taxes for the fiscal year related to the rate reduction.
Upon adoption of the new guidance on share-based payment awards, previously unrecognized excess tax benefits were recorded as a deferred tax asset, which was fully offset by a corresponding increase in valuation allowance, resulting in no impact to opening accumulated deficit.  In addition, due to the full valuation allowance on the U.S. deferred tax assets, there was no impact to the income tax provision from excess tax benefits for the three and nine months ended March 31, 2018
The income tax expense recorded differs from the expected tax expense (benefit) that would be calculated by applying the federal statutory rate to the Company’s income from continuing operations before taxes primarily due to the changes in valuation allowance for deferred tax assets attributable to the Company’s domestic and foreign income (loss) from continuing operations, impacts of the Act and due to the income tax benefit recorded in continuing operations under the income tax intraperiod allocation rules.
As of March 31, 2018, and July 1, 2017, the Company’s unrecognized tax benefits totaled $39.8 million and $38.9 million, respectively, and are included in deferred taxes and other non-current tax liabilities, net. The Company had $2.2 million accrued for the payment of interest and penalties at March 31, 2018. The unrecognized tax benefits that may be recognized during the next twelve months are approximately $0.6 million.