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INCOME TAXES
12 Months Ended
Jun. 30, 2020
Income Tax Disclosure [Abstract]  
INCOME TAXES INCOME TAXES
(Loss) income before income taxes from continuing operations in fiscal 2020, 2019 and 2018 is presented below:
Year Ended June 30,
202020192018
United States$(960.3)$(2,003.5)$(379.3)
Foreign(507.3)(1,941.9)(15.2)
Total$(1,467.6)$(3,945.4)$(394.5)
The components of the Company’s total (benefit) provision for income taxes from continuing operations during fiscal 2020, 2019 and 2018 are presented below:
Year Ended June 30,
202020192018
(Benefit) provision for income taxes from continuing operations:   
Current:   
Federal$ $0.8 $0.2 
State and local(0.3)8.2 9.8 
Foreign90.7 129.4 (33.9)
Total90.4 138.4 (23.9)
Deferred:   
Federal(286.7)(116.1)87.7 
State and local(50.6)(49.9)1.3 
Foreign(130.8)(27.2)(97.3)
Total(468.1)(193.2)(8.3)
Benefit for income taxes from continued operations$(377.7)$(54.8)$(32.2)

During fiscal 2020, the Company recorded a benefit of $105.7 for the capital loss generated as a result of the disposition of its investment in Younique.
During fiscal 2019, the Company recorded goodwill impairment that is not tax-deductible.
During fiscal 2018, the Company incurred an expense of $123.0 as a result of the Tax Act.
The reconciliation of the U.S. Federal statutory tax rate to the Company’s effective income tax rate during fiscal 2020, 2019 and 2018 is presented below:
Year Ended June 30,
202020192018
Income (loss) from continuing operations before income taxes$(1,467.6)$(3,945.4)$(394.5)
Benefit for income taxes at statutory rate$(308.2)$(828.5)$(110.7)
State and local taxes—net of federal benefit(28.0)(28.5)6.8 
Foreign tax differentials7.2 43.0 (22.7)
Change in valuation allowances7.4 (0.8)3.8 
Change in unrecognized tax benefit21.3 43.3 (26.7)
Tax Act  123.0 
Permanent differences—net14.3 5.0 (9.3)
Amortization on intercompany sale  1.9 
Goodwill impairment26.1 675.6  
Gain on sale of business adjustment(132.1)  
Other14.3 36.1 1.7 
Benefit for income taxes from continuing operations$(377.7)$(54.8)$(32.2)
Effective income tax rate25.7 %1.4 %8.2 %
Significant components of deferred income tax assets and liabilities as of June 30, 2020 and 2019 are presented below:
June 30,
2020
June 30,
2019
Deferred income tax assets:  
Inventories$14.2 $21.2 
Accruals and allowances66.9 50.5 
Sales returns12.9 16.0 
Share-based compensation10.1 11.1 
Employee benefits81.7 102.6 
Net operating loss carry forwards and tax credits446.5 268.4 
Capital loss carry forwards105.7  
Interest expense limitation carry forward122.1 52.3 
Lease liability22.6 8.0 
Other54.3 32.2 
Less: valuation allowances(40.0)(59.2)
Net deferred income tax assets897.0 503.1 
Deferred income tax liabilities:  
Intangible assets635.2 637.9 
Property, plant and equipment6.4 18.3 
Unrealized gain 0.5 
Licensing rights20.9 23.7 
Right of use asset32.0  
Other15.2 63.6 
Deferred income tax liabilities709.7 744.0 
Net deferred income tax asset (liability)$187.3 $(240.9)
The expirations of tax loss carry forwards, amounting to $2,075.5 as of June 30, 2020, in each of the fiscal years ending June 30, are presented below:
Fiscal Year Ending June 30,United StatesWestern EuropeRest of WorldTotal
2021$ $ $11.1 $11.1 
2022  3.5 3.5 
2023  5.6 5.6 
2024 0.1 7.0 7.1 
2025 and thereafter645.5 1,246.8 155.9 2,048.2 
Total$645.5 $1,246.9 $183.1 $2,075.5 
The total valuation allowances recorded are $40.0 and $59.2 as of June 30, 2020 and 2019, respectively. In fiscal 2020, the change in the valuation allowance was due primarily to valuation allowances released as a result of the underlying net operating losses either expiring or being written off due to the entity being liquidated.
A reconciliation of the beginning and ending amount of UTBs is presented below:
Year Ended June 30,
202020192018
UTBs—July 1$263.6 $235.7 $256.7 
Additions based on tax positions related to the current year15.9 43.9 43.6 
Additions for tax positions of prior years42.9 8.3 29.6 
Reductions for tax positions of prior years(27.6)(9.6)(39.9)
Settlements(0.1)(2.7)(42.3)
Lapses in statutes of limitations(12.7)(9.0)(10.4)
Foreign currency translation(4.1)(3.0)(1.6)
UTBs—June 30$277.9 $263.6 $235.7 
As of June 30, 2020, the Company had $277.9 of UTBs of which $150.1 represents the amount that, if recognized, would impact the effective income tax rate in future periods. As of June 30, 2020 and 2019, the liability associated with UTBs, including accrued interest and penalties, is $170.7 and $170.6, respectively, which is recorded in Income and other taxes payable and Other non-current liabilities in the Consolidated Balance Sheets.
During fiscal 2020, the Company accrued interest of $3.2, while in fiscal 2019 and 2018 the Company accrued interest of $4.3 and $1.5, respectively. During fiscal 2020, the Company accrued penalties of $0.0, while in fiscal 2019 and 2018 the Company accrued penalties of $0.0 and $0.4, respectively. The total gross accrued interest and penalties recorded in the Other noncurrent liabilities in the Consolidated Balance Sheets related to UTBs as of June 30, 2020 and 2019 is $19.3 and $16.7, respectively.
The Company is present in approximately 55 tax jurisdictions, and at any point in time is subject to several audits at various stages of completion. As a result, the Company evaluates tax positions and establishes liabilities for UTBs that may be challenged by local authorities and may not be fully sustained, despite a belief that the underlying tax positions are fully supportable. UTBs are reviewed on an ongoing basis and are adjusted in light of changing facts and circumstances, including progress of tax audits, developments in case law, and closing of statute of limitations. Such adjustments are reflected in the provision for income taxes as appropriate. In fiscal 2020 and 2019, the Company recognized a tax benefit of $12.8 and $11.7 respectively associated with the settlement of tax audits in multiple jurisdictions and the expiration of foreign and state statutes of limitation. The Company has open tax years ranging from 2009 and forward.
On the basis of information available at June 30, 2020, it is reasonably possible that a decrease of up to $33.2 in UTBs related to U.S. and foreign exposures may be necessary within the coming year. It is also possible the ongoing audits by tax authorities may result in increases or decreases to the balance of UTBs. Since it is common practice to extend audits beyond the Statute of Limitations, the Company is unable to predict the timing or conclusion of these audits and, accordingly, the Company is unable to estimate the amount of changes to the balance of UTBs that are reasonably possible at this time. However, the Company believes it has adequately provided for its UTBs for all open tax years in each tax jurisdiction.
On December 22, 2017, “H.R.1”, formerly known as the “Tax Cuts and Jobs Act” (“Tax Act”) was enacted. The Tax Act significantly revises the U.S. corporate income tax system by, amongst other things, reducing the federal tax rate on U.S. earnings to 21%, implementing a modified territorial tax system and imposing a one-time deemed repatriation tax on historical earnings generated by foreign subsidiaries that have not been repatriated to the U.S.
As a result of the 2017 Tax Act changing the U.S. to a modified territorial tax system, the Company no longer asserts that any of its undistributed foreign earnings are permanently reinvested. We do not expect to incur significant withholding or state taxes on future distributions. To the extent there remains a basis difference between the financial reporting and tax basis of an investment in a foreign subsidiary after the repatriation of the previously taxed income of $4,600.0, the Company is permanently reinvested.
On December 22, 2017, the SEC issued Staff Accounting Bulletin No. 118 (“SAB 118”) which provides guidance on accounting for the tax effects of the Tax Act. SAB 118 provides a measurement period that should not extend beyond one year from the enactment date of the Tax Act for companies to complete the accounting under ASC 740. The Company recorded its initial estimate of the impact of the Tax Act in fiscal 2018. This estimate was a charge of approximately $123.0 as a result of utilizing tax attributes (e.g., net operating losses and foreign tax credits) to fully offset the cash impact of the one-time deemed repatriation tax. During fiscal 2019, the Company finalized its estimate of the impact of the Tax Act and no additional adjustments were required.