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Note 11 - Income Taxes
12 Months Ended
Jun. 30, 2020
Notes to Financial Statements  
Income Tax Disclosure [Text Block]
1
1
. INCOME TAXES
 
 Components of earnings (loss) before income taxes are as follows (in thousands): 
 
   
2020
   
2019
   
2018
 
Domestic operations
  $
(24,450
)
  $
1,507
    $
1,351
 
Foreign operations
   
4,453
     
8,103
     
3,514
 
    $
(19,997
)
  $
9,610
    $
4,865
 
 
The provision for (benefit from) income taxes consists of the following (in thousands): 
 
   
2020
   
2019
   
2018
 
Current:
                       
Federal
  $
(19
)
  $
(106
)
  $
(991
)
Foreign
   
3,633
     
2,398
     
2,256
 
State
   
30
     
37
     
5
 
Deferred:
                       
Federal
   
(1,514
)
   
1,139
     
6,772
 
Foreign
   
53
     
(172
)
   
(396
)
State
   
(341
)
   
235
     
852
 
    $
1,842
    $
3,531
    $
8,498
 
 
Reconciliations of expected tax expense at the U.S. statutory rate to actual tax expense (benefit) are as follows (in thousands):
 
   
2020
   
2019
   
2018
 
Expected tax (benefit) expense
  $
(4,199
)
  $
2,018
    $
1,365
 
State taxes, net of federal effect
   
(1,042
)
   
(5
)
   
-
 
Foreign taxes, net of federal credits
   
1,210
     
(1,055
)
   
(1,010
)
Change in valuation allowance
   
1,996
     
1,744
     
2,074
 
Tax reserve adjustments
   
1,946
     
(66
)
   
(38
)
Return to provision and other adjustments
   
372
     
(57
)
   
(72
)
Goodwill impairment
   
130
     
-
     
-
 
Tax rate change applied to deferred tax balances
   
54
     
(129
)
   
6,324
 
Global intangible low taxed income
   
1,558
     
1,121
     
-
 
Other permanent items
   
(183
)
   
(40
)
   
(145
)
Actual tax (benefit) expense
  $
1,842
    $
3,531
    $
8,498
 
 
On
December 22, 2017,
the Tax Cuts and Jobs Act (“the Act”) was enacted in the United States. The Act reduces the U.S. federal corporate tax rate from a graduated rate of
35%
to a flat rate of
21%,
requires companies to pay a
one
-time transition tax on earnings of certain foreign subsidiaries that were previously tax deferred and creates new taxes on certain foreign sourced earnings. Accounting Standard Codification (“ASC”)
740
requires filers to record the effect of tax law changes in the period enacted. However, the SEC issued Staff Accounting Bulletin
No.
118
(“SAB
118”
), that permits filers to record provisional amounts during a measurement period ending
no
later than
one
year from the date of the Act's enactment.
 
During the fiscal year ended
June 30, 2018,
the Company recognized a provisional tax expense of
$6.3
million as a reasonable estimate of the impact of the provisions of the Act, which was included as a component of income tax expense in its Consolidated Statement of Operations. During the fiscal year ended
June 30, 2019,
the Company completed the accounting for the tax effects of the enactment of the Act. The Company recorded additional foreign tax credits of (
$1.8
) million which were offset by a valuation allowance, resulting in a
nil
adjustment to the provisional tax expense previously recorded.
 
Beginning in fiscal
2019,
the Company incorporated certain provisions of the Act in the calculation of the tax provision and effective tax rate, including the provisions related to the Global Intangible Low Taxed Income (“GILTI”), Foreign Derived Intangible Income (“FDII”), Base Erosion Anti Abuse Tax (“BEAT”), as well as other provisions, which limit tax deductibility of expenses. For fiscal
2020,
the GILTI provisions have the most significant impact to the Company. Under the new law, U.S. taxes are imposed on foreign income in excess of a deemed return on tangible assets of its foreign subsidiaries. In general, this foreign income will effectively be taxed at an additional
10.5%
tax rate reduced by any available current year foreign tax credits. The ability to benefit foreign tax credits
may
be limited under the GILTI rules as a result of the utilization of net operating losses, foreign sourced income and other potential limitations within the foreign tax credit calculation.
 
Interpretive guidance on the accounting for GILTI states that an entity can make an accounting policy election to either recognized deferred taxes for temporary basis differences expected to reverse as GILTI in future years or provide for the tax expense related to GILTI in the year the tax is incurred as a period expense only. The Company has made the accounting policy election to recognize GILTI as a period expense.
 
The Coronavirus Aid, Relief and Economic Security Act (the "CARES Act") was enacted in the United States on
March 27, 2020.
The CARES Act is an emergency economic stimulus package that includes spending and tax breaks to strengthen the United States economy and fund a nationwide effort to curtail the effect of COVID-
19.
While the CARES Act provides extensive tax changes in response to the COVID-
19
pandemic, the provisions are
not
expected to have a significant impact on the Company's financial results.
 
The tax rate of (
9.2%
) on pre-tax losses of (
$20.0
) million in the year ended
June 30, 2020
is lower than the U.S. statutory rate primarily as a result of the GILTI provisions, non-deductible goodwill impairment, as well as changes in the jurisdictional mix of earnings, particularly Brazil with a statutory tax rate of
34%.
The tax rate was also negatively impacted by the write-off of the long-term receivable previously established for competent authority relief for historic transfer pricing adjustments which the Company has determined is
no
longer feasible to pursue and an increase in the valuation allowance against foreign tax credits which the Company has determined are more likely than
not
to expire unutilized.
 
The tax rate of
36.7%
on pre-tax income of
$9.6
million in the year ended
June 30, 2019
is higher than the U.S. statutory rate primarily as a result of the GILTI provisions, which became effective in fiscal
2019,
as well as changes in the jurisdictional mix of earnings, particularly Brazil with a statutory tax rate of
34%.
 
The tax rate of
174.7%
on pre-tax income of
$4.9
million in the year ended
June 30, 2018
is higher than the U.S. statutory rate primarily as a result of the impact of the corporate tax rate reduction on the Company's net deferred tax assets. Excluding the impacts of tax reform, the tax rate of
44.7%
for fiscal
2018
is higher than the U.S. statutory rate primarily as a result of an increase in the valuation allowance against foreign tax credits and state net operating loss carryforwards which the Company has determined are more likely than
not
to expire unutilized.
 
Net deferred tax assets at
June 30, 2020
were
$21.0
million. While these deferred tax assets reflect the tax effect of temporary differences between book and taxable income in all jurisdictions in which the Company has operations, the majority of the assets relate to U.S. operations. U.S. net deferred assets are
$26.9
million with a valuation allowance of
$8.8
 million. The Company has considered the positive and negative evidence to determine the need for a valuation allowance offsetting the deferred tax assets in the U.S. and has concluded that a partial valuation allowance is required against foreign tax credit carryforwards due to the uncertainty of generating sufficient foreign source income to utilize those credits in the future and certain state net operating loss carryforward that will expire in the near future.
 
Key positive evidence considered include: a) domestic profitability in
2019
and
2018;
b) cost saving plans are being implemented by the Company; c) indefinite federal loss carryforward periods and d) forecasted domestic profits for future years. The negative evidence considered is that fiscal years
2020
showed domestic book and tax losses due to the impact of the COVID-
19
pandemic and charges recorded in the
fourth
quarter.
 
In fiscal
2020,
the valuation allowance increased by
$2.1
million due to the impact of the current year domestic loss generated and revised forecasts of income on the projected utilization of foreign tax credits that will expire at various dates through
2028.
In fiscal
2019,
the valuation allowance increased by
$1.7
million primarily due to an increase in foreign tax credits that became available as a result of the
one
-time transition tax on foreign earnings, in excess of the limitation on their use as a result of the Company's overall domestic loss recapture.
 
Deferred income taxes at
June 30, 2020
and
2019
are attributable to the following (in thousands): 
 
   
2020
   
2019
 
Inventories
  $
1,339
    $
1,361
 
Employee benefits (other than pension)
   
684
     
840
 
Operating lease liabilities
   
1,111
     
-
 
Book reserves
   
695
     
601
 
Federal NOL, various carryforward periods
   
716
     
66
 
State NOL, various carryforward periods
   
1,719
     
1,224
 
Foreign NOL, various carryforward periods
   
388
     
309
 
Foreign tax credit carryforward, expiring 2023 – 2028
   
7,212
     
7,329
 
Pension benefits
   
13,175
     
10,289
 
Retiree medical benefits
   
1,961
     
1,778
 
Depreciation
   
(186
)
   
(17
)
Intangibles
   
580
     
(630
)
Right of use assets
   
(1,088
)
   
-
 
Federal research and development and AMT credit carryforward
   
817
     
786
 
Other temporary taxable differences
   
(698
)
   
-
 
Other temporary deductible differences
   
1,404
     
1,446
 
Total deferred tax assets
   
29,828
     
25,382
 
Valuation allowance
   
(8,811
)
   
(6,743
)
Net deferred tax asset
  $
21,018
    $
18,639
 
 
The Company is subject to U.S. federal income tax and various state, local and foreign income taxes in numerous jurisdictions. The Company's domestic and international tax liabilities are subject to the allocation of revenues and expenses in different jurisdictions and the timing of recognizing revenues and expenses. Additionally, the amount of income taxes paid is subject to the Company's interpretation of applicable tax laws in the jurisdictions in which it files. Reconciliations of the beginning and ending amount of unrecognized tax benefits are as follows (in thousands): 
 
Balance at July 1, 2017
  $
(11,588
)
Increase for tax positions taken during the current period
   
(287
)
Increase for tax positions taken during the prior period
   
(67
)
Effect of exchange rate changes
   
130
 
Decrease relating to lapse of applicable statute of limitations
   
930
 
Balance at June 30, 2018
   
(10,882
)
         
Increase for tax positions taken during the current period
   
(215
)
Decrease for tax positions taken during the prior period
   
5
 
Effect of exchange rate changes
   
16
 
Decrease relating to lapse of applicable statute of limitations
   
137
 
Balance at June 30, 2019
   
(10,939
)
         
Increase for tax positions taken during the current period
   
(326
)
Increase for tax positions taken during the prior period
   
(188
)
Effect of exchange rate changes
   
299
 
Decrease relating to lapse of applicable statute of limitations
   
48
 
Balance at June 30, 2020
  $
(11,106
)
 
As of
June 30, 2020,
2019
and
2018,
the Company has unrecognized tax benefits of
$11.1
million,
$10.9
million, and
$10.9
million, respectively, of which
$7.7
million,
$5.6
million and
$5.4
million, respectively, would favorably impact the effective tax rate if recognized.
 
The long-term tax obligations as of
June 30, 2020,
2019
and
2018
relate primarily to transfer pricing adjustments. The Company has also recorded a non-current tax receivable for
$0.0
million and
$1.7
million at
June 30, 2020
and
2019,
respectively, representing the corollary effect of transfer pricing competent authority adjustments.
 
The Company has identified uncertain tax positions at
June 30, 2020
for which it is possible that the total amount of unrecognized tax benefits will decrease within the next
twelve
months by
$0.1
million. The Company recognizes interest and penalties related to income tax matters in income tax expense and has booked
$0.1
million in fiscal
2020
for interest expense.
 
The Company's U.S. federal tax returns for years prior to fiscal
2017
are
no
longer subject to U.S. federal examination by the Internal Revenue Service; however, tax losses and credits carried forward from earlier years are still subject to review and adjustment. As of
June 30, 2020,
the Company has resolved all open income tax audits. In international jurisdictions, the years that
may
be examined vary by country. The Company's most significant foreign subsidiary in Brazil is subject to audit for the calendar years
2015
through
2019.
 
The federal tax loss carryforward of
$3.4
million has an unlimited carryforward period. The state tax loss carryforwards tax effected benefit of
$1.7
million expires at various times beginning in
2021.
The state tax credit carryforwards of
$0.6
million expires in the years
2021
through
2035.
The foreign tax credit carryforward of
$7.2
million expires in the years
2023
through
2028.
The research and development tax credit carryforward of
$0.8
million expires in the years
2029
through
2040.
The foreign tax loss carryforwards of
$2.3
million can be carried forward indefinitely.
 
At
June 30, 2020,
the estimated amount of total unremitted earnings of foreign subsidiaries is
$56.4
million. The Company has
no
plans to repatriate prior year earnings of its foreign subsidiaries and, accordingly, does
not
believe it is practicable to estimate the unrecognized deferred taxes related to these earnings as they are indefinitely reinvested. Cash held in foreign subsidiaries is
not
available for use in the U.S. without the likely incurrence of U.S. federal and state income and withholding tax consequences.