INCOME TAXES

12 Months Ended

Jun. 30, 2023

Income Tax Disclosure [Abstract]

INCOME TAXES

INCOME TAXES

Income (loss) from continuing operations before income taxes in fiscal 2023, 2022 and 2021 is presented below:

	Year Ended June 30,
	2023		2022		2021
United States	$	(253.6)	$	(277.5)	$	(434.4)
Foreign	958.4		704.3		194.6
Total	$	704.8	$	426.8	$	(239.8)

The components of the Company’s total provision (benefit) for income taxes from continuing operations during fiscal 2023, 2022 and 2021 are presented below:

	Year Ended June 30,
	2023		2022		2021
Provision (benefit) for income taxes on continuing operations:
Current:
Federal	$	2.6	$	6.6	$	3.8
State and local	2.6		(6.0)		14.9
Foreign	120.1		152.1		55.2
Total	125.3		152.7		73.9
Deferred:
Federal	(61.1)		(2.7)		41.1
State and local	1.0		(12.8)		5.4
Foreign	116.4		27.6		(292.4)
Total	56.3		12.1		(245.9)
Provision (benefit) for income taxes on continuing operations	$	181.6	$	164.8	$	(172.0)

During fiscal 2023, the Company recorded a provision of $181.6 primarily due to the limitation on the deductibility of executive stock compensation, offset by fair value gains related to the investment in the Wella business at a lower rate.

During fiscal 2022, the Company recorded a provision of $164.8 primarily due to the limitation on the deductibility of executive stock compensation and tax costs associated with the Russia exit, offset by large fair value gains related to the investment in the Wella business at a lower rate.

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 equity investment in Wella.

The reconciliation of the U.S. Federal statutory tax rate to the Company’s effective income tax rate during fiscal 2023, 2022 and 2021 is presented below:

	Year Ended June 30,
	2023			2022			2021
Income (loss) from continuing operations before income taxes	$	704.8		$	426.8		$	(239.8)
Provision (benefit) for income taxes at statutory rate	$	148.0		$	89.6		$	(50.4)
State and local taxes—net of federal benefit	2.8			(14.9)			26.3
Foreign tax differentials	(10.1)			(16.4)			(23.3)
Change in valuation allowances	10.2			(2.3)			(3.8)
Change in unrecognized tax benefit	32.5			(10.6)			(18.0)
Permanent differences—net	(4.9)			25.4			(13.1)
Non-deductible executive stock compensation	27.7			37.1			—
Currency Loss	(13.6)			(0.2)			—
Dispositions of business assets	—			12.7			—
Russia exit	(7.0)			24.1			—
Principal relocation	—			—			(234.4)
Post-divestiture restructuring	—			—			130.0
Other	(4.0)			20.3			14.7
Provision (benefit) for income taxes on continuing operations	$	181.6		$	164.8		$	(172.0)
Effective income tax rate	25.8		%	38.6		%	71.7		%

Significant components of deferred income tax assets and liabilities as of June 30, 2023 and 2022 are presented below:

	June 30, 2023		June 30, 2022
Deferred income tax assets:
Inventories	$	7.5	$	8.3
Accruals and allowances	54.9		58.6
Sales returns	19.1		17.3
Share-based compensation	4.8		5.1
Employee benefits	55.6		60.3
Net operating loss carry forwards and tax credits	241.4		296.4
Capital loss carry forwards	0.3		1.1
Interest expense limitation carry forward	47.5		28.5
Lease liability	28.6		30.6
Principal relocation lease liability	424.0		434.0
Property, plant and equipment	13.0		—
Other	48.4		31.7
Less: valuation allowances	(60.7)		(41.7)
Net deferred income tax assets	884.4		930.2
Deferred income tax liabilities:
Intangible assets	817.4		811.9
Property, plant and equipment	—		9.2
Licensing rights	27.8		25.7
Right of use asset	28.6		31.2
Other	80.5		69.4
Deferred income tax liabilities	954.3		947.4
Net deferred income tax (liability) asset	$	(69.9)	$	(17.2)

The expirations of tax loss carry forwards, amounting to $686.9 as of June 30, 2023, 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
2024	$	—	$	7.9	$	0.6	$	8.5
2025	—		3.1		3.9		7.0
2026	—		—		9.5		9.5
2027	—		245.9		27.8		273.7
2028 and thereafter	—		115.5		272.7		388.2
Total	$	—	$	372.4	$	314.5	$	686.9

The total valuation allowances recorded are $60.7 and $41.7 as of June 30, 2023 and 2022, respectively. In fiscal 2023, the change in the valuation allowance was primarily due to an increase in valuation allowance on certain state and foreign net operating losses.

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

	Year Ended June 30,
	2023		2022		2021
UTBs—July 1	$	251.6	$	279.9	$	277.9
Additions based on tax positions related to the current year	6.7		1.7		32.1
Additions for tax positions of prior years	0.7		20.8		—
Reductions for tax positions of prior years	(1.4)		(29.4)		(4.5)
Settlements	(4.6)		(0.2)		(0.4)
Lapses in statutes of limitations	(13.8)		(14.1)		(33.3)
Foreign currency translation	(3.7)		(7.1)		8.1
UTBs—June 30	$	235.5	$	251.6	$	279.9

As of June 30, 2023, the Company had $235.5 of UTBs of which $184.9 represents the amount that, if recognized, would impact the effective income tax rate in future periods. As of June 30, 2023 and 2022, the liability associated with UTBs, including accrued interest and penalties, is $218.6 and $191.8, respectively, which is recorded in Income and other taxes payable and Other non-current liabilities in the Consolidated Balance Sheets.

The Company accrued interest of $7.8, $4.2 and $0.8, respectively, in fiscal 2023, 2022 and 2021. The Company accrued immaterial penalties in fiscal 2023 and no penalties in fiscal 2022, and released penalties of $0.5 in fiscal 2021. 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, 2023 and 2022 is $33.1 and $26.4, respectively.

The Company is present in approximately 40 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 2023 and 2022, the Company recognized a tax benefit of $18.4 and $14.3 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, 2023, it is reasonably possible that a decrease of up to $21.5 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.