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Income Taxes
12 Months Ended
Sep. 30, 2020
Income Tax Disclosure [Abstract]  
Income Taxes

9.  Income Taxes

Income taxes in the accompanying consolidated statements of operations were as follows:

 

 

Fiscal Year

 

(In thousands)

 

2020

 

 

2019

 

 

2018

 

Current (benefit) provision:

 

 

 

 

 

 

 

 

 

 

 

 

U.S. Federal

 

$

(1,570

)

 

$

1,355

 

 

$

(890

)

U.S. State

 

 

42

 

 

 

192

 

 

 

51

 

International

 

 

90

 

 

 

41

 

 

 

41

 

Total current (benefit) provision

 

 

(1,438

)

 

 

1,588

 

 

 

(798

)

Deferred (benefit) provision:

 

 

 

 

 

 

 

 

 

 

 

 

U.S. Federal

 

 

(1,336

)

 

 

(1,505

)

 

 

(2,006

)

U.S. State

 

 

197

 

 

 

(117

)

 

 

(271

)

International

 

 

 

 

 

 

 

 

 

Total deferred benefit (1)

 

 

(1,139

)

 

 

(1,622

)

 

 

(2,277

)

Total income tax benefit

 

$

(2,577

)

 

$

(34

)

 

$

(3,075

)

 

 

(1)

Both the current and deferred benefit include the impact of the adoption of ASC Topic 606 in fiscal 2019, which reduced deferred income taxes and income taxes receivable by $1.2 million and $0.4 million, respectively, as of adoption (Note 2).

The following is a reconciliation of the difference between amounts calculated at the statutory U.S. federal income tax rate of 21%, 21% and 24.5% for fiscal 2020, 2019 and 2018, respectively, and the Company’s effective tax rate:

 

 

 

Fiscal Year

 

(In thousands)

 

2020

 

 

2019

 

 

2018

 

Amount at statutory U.S. federal income tax rate

 

$

(305

)

 

$

1,587

 

 

$

(1,845

)

Change because of the following items:

 

 

 

 

 

 

 

 

 

 

 

 

State income taxes, net of federal benefit

 

 

(551

)

 

 

(452

)

 

 

(724

)

U.S. Federal and foreign research and development

    credits

 

 

(1,571

)

 

 

(2,464

)

 

 

(1,710

)

Foreign and state rate differential

 

 

212

 

 

 

156

 

 

 

371

 

Valuation allowance change

 

 

825

 

 

 

671

 

 

 

960

 

Stock-based compensation (1)

 

 

(81

)

 

 

(163

)

 

 

(2,063

)

Contingent consideration (gain) expense and related

    foreign currency revaluation

 

 

 

 

 

(61

)

 

 

142

 

U.S. Federal and state rate change

 

 

17

 

 

 

44

 

 

 

1,582

 

Tax reserve change

 

 

609

 

 

 

770

 

 

 

158

 

Foreign-derived income deduction

 

 

(88

)

 

 

(150

)

 

 

 

Impact of CARES Act

 

 

(1,700

)

 

 

 

 

 

 

Other

 

 

56

 

 

 

28

 

 

 

54

 

Income tax benefit

 

$

(2,577

)

 

$

(34

)

 

$

(3,075

)

 

 

 

 

 

 

 

 

 

 

 

 

 

 

(1)

Includes non-deductible stock-based compensation.

In March 2020, the Coronavirus Aid, Relief and Economic Security Act (the “CARES Act”) was enacted and included significant business tax provisions. In particular, the CARES Act modified the rules associated with net operating losses (“NOLs”) and made technical corrections to tax depreciation methods for qualified improvement property. Under the temporary provisions of CARES Act, NOL carryforwards and carrybacks may offset 100% of taxable income for taxable years beginning before 2021. In addition, NOLs arising in 2018, 2019 and 2020 taxable years may be carried back to each of the preceding five years to generate a refund. In fiscal 2020, the income tax benefit includes a discrete tax benefit of $1.7 million as a result of our ability under the CARES Act to carry back NOLs incurred to periods when the statutory tax rate was 35% versus our current tax rate of 21%.

In December 2017, the Tax Cuts and Jobs Act (“TCJA”) tax legislation was signed into law, which reduced the U.S. federal statutory tax rate from 35% to 21%, among other changes. As of September 30, 2019, the Company had fully completed its accounting for the tax effects of the enactment of the TCJA. The fiscal 2018 income tax benefit includes discrete tax expense of $1.6 million from the revaluation of the Company’s net deferred tax assets based on the enacted tax rate of 21%, compared to the previous rate of 35%. U.S. tax law requires that taxpayers with a fiscal year beginning before and ending after the effective date of a rate change calculate a blended tax rate for the year based on the pro rata number of days in the year before and after such effective date. As a result, for fiscal 2018, our U.S. federal income tax rate was 24.5%.

Excess tax benefits related to stock-based compensation expense are recorded within income tax benefit in the consolidated statements of operations and totaled $0.4 million, $0.5 million and $2.0 million for fiscal 2020, 2019 and 2018, respectively.

The components of deferred income taxes consisted of the following and result from differences in the recognition of transactions for income tax and financial reporting purposes:

 

 

September 30,

 

(In thousands)

 

2020

 

 

2019

 

Depreciable assets

 

$

(1,964

)

 

$

(905

)

Deferred revenue

 

 

2,029

 

 

 

1,554

 

Accruals and reserves

 

 

1,858

 

 

 

585

 

Stock-based compensation

 

 

2,232

 

 

 

2,213

 

Impaired strategic investments

 

 

1,767

 

 

 

1,666

 

NOL carryforwards

 

 

3,526

 

 

 

3,308

 

U.S. Federal and State R&D credits

 

 

3,216

 

 

 

2,394

 

Other

 

 

897

 

 

 

689

 

Valuation allowance

 

 

(6,246

)

 

 

(5,328

)

Total deferred tax assets

 

$

7,315

 

 

$

6,176

 

 

 

 

 

 

 

 

 

 

As of September 30, 2020 and 2019, deferred tax asset valuation allowances totaled $6.2 million and $5.3 million, respectively. The valuation allowances were primarily related to other-than-temporary impairment losses on strategic investments, state R&D credit carryforwards, and NOL carryforwards of Creagh Medical. As of September 30, 2020, the Company had federal and state R&D credit carryforwards of $3.2 million that will begin expiring in fiscal 2029 and U.S. federal and state NOL carryforwards of $0.1 million and $0.2 million tax-effected, respectively, that will begin expiring in fiscal 2034 and fiscal 2022, respectively. Ireland NOL carryforward tax assets totaled $3.2 million as of September 30, 2020, much of which was acquired as part of the Creagh Medical acquisition in fiscal 2016, and have an unlimited carryforward period. The U.S. federal and Minnesota NOLs acquired as part of the NorMedix acquisition are subject to the Internal Revenue Code Section 382 limitation rules.

Unrecognized tax benefits are the differences between a tax position taken, or expected to be taken in a tax return, and the benefit recognized for accounting purposes pursuant to accounting guidance. The following is a reconciliation of the changes in unrecognized tax benefits, excluding interest and penalties:

 

 

 

Fiscal Year

 

(In thousands)

 

2020

 

 

2019

 

 

2018

 

Unrecognized tax benefits, beginning balance

 

$

2,323

 

 

$

1,559

 

 

$

1,481

 

Increases in tax positions for prior years

 

 

58

 

 

 

278

 

 

 

61

 

Decreases in tax positions for prior years

 

 

(1

)

 

 

(2

)

 

 

 

Increases in tax positions for current year

 

 

664

 

 

 

735

 

 

 

735

 

Settlements with taxing authorities

 

 

 

 

 

 

 

 

(613

)

Lapse of the statute of limitations

 

 

(173

)

 

 

(247

)

 

 

(105

)

Unrecognized tax benefits, ending balance

 

$

2,871

 

 

$

2,323

 

 

$

1,559

 

 

 

 

 

 

 

 

 

 

 

 

 

 

The total amount of unrecognized tax benefits excluding interest and penalties that, if recognized, would affect the effective tax rate was $2.7 million, $2.1 million and $1.4 million as of September 30, 2020, 2019 and 2018, respectively. Currently, the Company does not expect the liability for unrecognized tax benefits to change significantly in the next 12 months and has classified the above balances on the consolidated balance sheets in other long-term liabilities. Interest and penalties related to unrecognized tax benefits are recorded in income tax expense. As of September 30, 2020, 2019 and 2018, the gross amount accrued for interest and penalties on unrecognized tax benefits was $0.6 million, $0.5 million and $0.4 million, respectively.

The Company files income tax returns, including returns for its subsidiaries, in the U.S. federal jurisdiction and in various state jurisdictions, as well as several non-U.S. jurisdictions. Uncertain tax positions are related to tax years that remain subject to examination. U.S. federal income tax returns for years prior to fiscal 2017 are no longer subject to examination by federal tax authorities. For tax returns for state and local jurisdictions, the Company is no longer subject to examination for tax years generally before fiscal 2009. For tax returns for non-U.S. jurisdictions, the Company is no longer subject to income tax examination for years prior to 2014. Additionally, the Company has been indemnified of liability for any taxes relating to Creagh Medical and NorMedix for periods prior to the respective acquisition dates, pursuant to the terms of the related share purchase agreements. As of September 30, 2020 and 2019, there were no undistributed earnings in foreign subsidiaries.