INCOME TAXES

12 Months Ended

Jun. 30, 2021

Income Tax Disclosure [Abstract]

INCOME TAXES

INCOME TAXES

(Loss) income before income taxes from continuing operations in fiscal 2021, 2020 and 2019 is presented below:

	Year Ended June 30,
	2021		2020		2019
United States	$	(434.4)	$	(960.3)	$	(2,003.5)
Foreign	194.6		(507.3)		(1,941.9)
Total	$	(239.8)	$	(1,467.6)	$	(3,945.4)

The components of the Company’s total (benefit) provision for income taxes from continuing operations during fiscal 2021, 2020 and 2019 are presented below:

	Year Ended June 30,
	2021		2020		2019
(Benefit) provision for income taxes from continuing operations:
Current:
Federal	$	3.8	$	—	$	0.8
State and local	14.9		(0.3)		8.2
Foreign	55.2		90.7		129.4
Total	73.9		90.4		138.4
Deferred:
Federal	41.1		(286.7)		(116.1)
State and local	5.4		(50.6)		(49.9)
Foreign	(292.4)		(130.8)		(27.2)
Total	(245.9)		(468.1)		(193.2)
Benefit for income taxes from continued operations	$	(172.0)	$	(377.7)	$	(54.8)

During fiscal 2021, the Company recorded a benefit of $234.4 as a result of a tax rate differential on the deferred taxes recognized on the transfer of assets and liabilities, following the Company’s relocation of the main principal location from Geneva to Amsterdam. The overall value of the assets and liabilities transferred was negotiated with both the Swiss and Dutch tax authorities and per terms of the agreements, will be reevaluated after three years. The Company also recorded an expense of

$130.0 related to an internal restructuring following the Wella divestiture, primarily intended to create a more efficient structure to hold its remaining 40% equity investment in Wella.

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.

The reconciliation of the U.S. Federal statutory tax rate to the Company’s effective income tax rate during fiscal 2021, 2020 and 2019 is presented below:

	Year Ended June 30,
	2021			2020			2019
Income (loss) from continuing operations before income taxes	$	(239.8)		$	(1,467.6)		$	(3,945.4)
Benefit for income taxes at statutory rate	$	(50.4)		$	(308.2)		$	(828.5)
State and local taxes—net of federal benefit	26.3			(28.0)			(28.5)
Foreign tax differentials	(23.3)			7.2			43.0
Change in valuation allowances	(3.8)			7.4			(0.8)
Change in unrecognized tax benefit	(18.0)			21.3			43.3
Permanent differences—net	(13.1)			14.3			5.0
Goodwill impairment	—			26.1			675.6
Principal relocation	(234.4)
Post-divestiture restructuring	130.0
Gain on sale of business adjustment	—			(132.1)			—
Other	14.7			14.3			36.1
Benefit for income taxes from continuing operations	$	(172.0)		$	(377.7)		$	(54.8)
Effective income tax rate	71.7		%	25.7		%	1.4		%

Significant components of deferred income tax assets and liabilities as of June 30, 2021 and 2020 are presented below:

	June 30, 2021		June 30, 2020
Deferred income tax assets:
Inventories	$	9.7	$	14.2
Accruals and allowances	86.4		66.9
Sales returns	16.4		12.9
Share-based compensation	5.8		10.1
Employee benefits	101.6		81.7
Net operating loss carry forwards and tax credits	295.4		446.5
Capital loss carry forwards	1.1		105.7
Interest expense limitation carry forward	15.5		122.1
Lease liability	24.3		22.6
Principal relocation lease liability	487.8		—
Property, plant and equipment	7.7		—
Other	36.8		54.3
Less: valuation allowances	(33.4)		(40.0)
Net deferred income tax assets	1,055.1		897.0
Deferred income tax liabilities:
Intangible assets	892.1		635.2
Property, plant and equipment	—		6.4
Licensing rights	23.3		20.9
Right of use asset	27.4		32.0
Other	28.7		15.2
Deferred income tax liabilities	971.5		709.7
Net deferred income tax asset	$	83.6	$	187.3

The expirations of tax loss carry forwards, amounting to $1,343.8 as of June 30, 2021, in each of the fiscal years ending June 30, are presented below:

Fiscal Year Ending June 30,	United States		Western Europe		Rest of World		Total
2022	$	—	$	—	$	4.0	$	4.0
2023	—		—		2.1		2.1
2024	—		—		5.5		5.5
2025	—		71.9		15.3		87.2
2026 and thereafter	—		1,050.4		194.6		1,245.0
Total	$	—	$	1,122.3	$	221.5	$	1,343.8

The total valuation allowances recorded are $33.4 and $40.0 as of June 30, 2021 and 2020, respectively. In fiscal 2021, the change in the valuation allowance was due primarily to valuation allowances released as a result of the underlying net operating losses expiring.

A reconciliation of the beginning and ending amount of UTBs is presented below:

	Year Ended June 30,
	2021		2020		2019
UTBs—July 1	$	277.9	$	263.6	$	235.7
Additions based on tax positions related to the current year	32.1		15.9		43.9
Additions for tax positions of prior years	—		42.9		8.3
Reductions for tax positions of prior years	(4.5)		(27.6)		(9.6)
Settlements	(0.4)		(0.1)		(2.7)
Lapses in statutes of limitations	(33.3)		(12.7)		(9.0)
Foreign currency translation	8.1		(4.1)		(3.0)
UTBs—June 30	$	279.9	$	277.9	$	263.6

As of June 30, 2021, the Company had $279.9 of UTBs of which $161.7 represents the amount that, if recognized, would impact the effective income tax rate in future periods. As of June 30, 2021 and 2020, the liability associated with UTBs, including accrued interest and penalties, is $181.2 and $170.7, respectively, which is recorded in Income and other taxes payable and Other non-current liabilities in the Consolidated Balance Sheets.

During fiscal 2021, the Company accrued interest of $0.8, while in fiscal 2020 and 2019 the Company accrued interest of $3.2 and $4.3, respectively. During fiscal 2021, the Company released penalties of $0.5, while in fiscal 2020 and 2019 the Company accrued penalties of $0.0 and $0.0, 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, 2021 and 2020 is $21.7 and $19.3, respectively.

The Company is present in approximately 50 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 2021 and 2020, the Company recognized a tax benefit of $33.7 and $12.8 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, 2021, it is reasonably possible that a decrease of up to $21.7 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.