INCOME TAXES

In Q4 2018, the U.S. government enacted comprehensive tax legislation commonly referred to as the Tax Cuts and Jobs Act (the “Tax Act”). The Tax Act, which was effective January 1, 2018 made broad and complex changes to the U.S. tax code. Following is a summary of the key corporate income tax provisions of the Tax Act:


•	reduced the U.S. federal corporate income tax rate from 35% to 21%,


•	implemented a one-time tax on the deemed repatriation of undistributed non-U.S. subsidiary earnings and generally eliminated the U.S. federal corporate income taxes on dividends from foreign subsidiaries,


•	included global intangible low-taxed income ("GILTI") provisions, which impose a tax on foreign income in excess of a deemed return on tangible assets of foreign corporations, and


•	included base-erosion and anti-abuse tax ("BEAT") provisions, which eliminate the deduction of certain base-erosion payments made to related foreign corporations, and imposed a minimum tax if greater than regular tax.

In 2018, pursuant to Securities and Exchange Commission Staff Accounting Bulletin No. 118 (“SAB 118”), we recorded a provisional tax expense associated with the Tax Act of $27.9. This charge was primarily associated with a remeasurement of deferred tax assets and the net tax impact of the tax on deemed repatriation. In 2019, we recognized $1.6 of discrete tax benefits associated with finalization of our accounting for the Tax Act.

In 2019, we finalized our policy and elected to use the period cost method for the tax on GILTI provisions and therefore did not record deferred taxes for basis differences expected to reverse in future periods. We were not required to record income taxes under the BEAT provisions in 2019.

Provision for Income Taxes

The provision for income taxes on income before income taxes consists of:



Provision for Income Taxes—Expense	Year Ended
Provision for Income Taxes—Expense	February 22, 2019			February 23, 2018		February 24, 2017
Current income taxes:
Federal	$	18.4		$	15.0	$	18.4
State and local	6.0			0.8		9.5
Foreign	14.6			12.1		17.0
	39.0			27.9		44.9
Deferred income taxes:
Federal	(3.6		)	37.9		21.4
State and local	1.2			7.0		1.2
Foreign	1.3			8.0		4.2
	(1.1		)	52.9		26.8
Income tax expense	$	37.9		$	80.8	$	71.7

Income taxes were based on the following sources of income before income tax expense:



Source of Income Before Income Tax Expense	Year Ended
Source of Income Before Income Tax Expense	February 22, 2019		February 23, 2018		February 24, 2017
Domestic	$	119.4	$	120.2	$	136.0
Foreign	44.5		41.3		60.3
	$	163.9	$	161.5	$	196.3

The total income tax expense we recognized is reconciled to that computed by applying the U.S. federal statutory tax rate of 21.0% for 2019 and 32.9% for 2018 and 35.0% for 2017, as follows:



Income Tax Provision Reconciliation	Year Ended
Income Tax Provision Reconciliation	February 22, 2019			February 23, 2018			February 24, 2017
Tax expense at the U.S. federal statutory rate	$	34.4		$	53.2		$	68.7
Impact of the Tax Act (1)	(1.6		)	27.9			—
State and local income taxes, net of federal	5.7			6.7			6.5
Valuation allowance provisions and adjustments (2)	(1.3		)	0.4			(2.2		)
Foreign investment tax credits (3)	—			(1.6		)	—
COLI income (4)	(1.6		)	(3.4		)	(3.3		)
Foreign operations, less applicable foreign tax credits (5)	7.8			1.4			(2.0		)
Impact of change to non-U.S. federal statutory tax rates (6)	(0.8		)	4.0			9.3
Research tax credit	(2.9		)	(2.3		)	(1.8		)
Tax reserve adjustments (7)	—			(0.2		)	(5.3		)
Other	(1.8		)	(5.3		)	1.8
Total income tax expense recognized	$	37.9		$	80.8		$	71.7

________________________

(1)

We remeasured certain deferred tax assets and liabilities based on the rates at which they are expected to reverse in the future, which are generally 21.0%. Those items that reversed in 2018 were remeasured using a tax rate of 32.9%. We recorded a provisional decrease to deferred tax assets of $23.9 attributable to the rate reduction and a provisional tax liability of $4.0 related to transition tax for 2018. During 2019, we recorded adjustments reducing the impact of the rate change and the transition tax by $1.0 and $0.6 respectively, representing a tax rate reduction of 1%.


(2)	The valuation allowance provisions were based on current year activity, and the valuation allowance adjustments were based on various factors, which are further detailed below.


(3)	Investment tax credits were granted by the Czech Republic for investments in qualifying manufacturing equipment.


(4)	The increase in the cash surrender value of COLI policies, net of normal insurance expenses, plus death benefit gains are non-taxable.


(5)	The foreign operations, less applicable foreign tax credits, amounts include the rate differential between local statutory rates and the U.S. rate on foreign operations.


(6)	Reductions to the French corporate tax rate resulted in the revaluation of certain deferred tax assets of our French tax group, causing an increase to income tax expense of $4.0 and $7.9 in 2018 and 2017, respectively. During 2017, reductions to the United Kingdom corporate tax rate increased tax expense by $1.5.


(7)	Adjustments in 2017 related to a French income tax audit that was settled in 2017.

Deferred Income Taxes

The significant components of deferred income taxes are as follows:



Deferred Income Taxes	February 22, 2019			February 23, 2018
Deferred income tax assets:
Employee benefit plan obligations and deferred compensation	$	59.2		$	55.8
Foreign and domestic net operating loss carryforwards	46.1			55.8
Reserves and accruals	16.2			18.9
Tax credit carryforwards	38.7			31.8
Other, net	17.4			16.1
Total deferred income tax assets	177.6			178.4
Valuation allowances	(7.8		)	(9.5		)
Net deferred income tax assets	169.8			168.9
Deferred income tax liabilities:
Property, plant and equipment	29.4			28.4
Intangible assets	10.6			3.4
Prepaid expenses	2.2			1.7
Total deferred income tax liabilities	42.2			33.5
Net deferred income taxes	$	127.6		$	135.4
Net deferred income taxes is comprised of the following components:
Deferred income tax assets—non-current	135.8			135.4
Deferred income tax liabilities—non-current	8.2			—

At February 22, 2019, the valuation allowance of $7.8 included $5.8 relating to foreign deferred tax assets. In updating our assessment of the ultimate realization of deferred tax assets, we considered the following factors:


•	the nature, frequency and severity of cumulative losses in recent years,


•	the predictability of future income,


•	prudent and feasible tax planning strategies that could be implemented to protect the loss of the deferred tax assets and


•	the effect of reversing taxable temporary differences.

Based on our evaluation of these factors, particularly cumulative losses, we were unable to assert that it is more likely than not that the deferred tax assets in our owned dealers and sales offices in France, the United Kingdom, Singapore, Hong Kong and Brazil would be realized as of February 22, 2019. During 2019 we determined that it was more likely than not that all of our tax credits in the Czech Republic would be utilized prior to their expiration, and the reversal of the partial valuation allowance on these credits reduced tax expense by $1.7.

As a result of the Tax Act, we have the ability to repatriate cash associated with foreign subsidiary earnings to our U.S. parent without incurring additional U.S. federal income tax, as these earnings were subject to U.S. federal income taxes in 2018. However, this cash may be subject to foreign withholding taxes and/or U.S. state and local taxes if repatriated to the U.S. We have provided deferred income taxes for those amounts on earnings of subsidiaries expected to be distributed. However, we have not recorded deferred taxes on any remaining historical outside basis differences in non-U.S. subsidiaries as we continue to assert indefinite reinvestment on outside basis differences not related to amounts that have been previously taxed in the U.S. or undistributed earnings generated after 2018.

Taxes Payable or Refundable

Income taxes currently payable or refundable are reported on the Consolidated Balance Sheets as follows:



Income Taxes	February 22, 2019		February 23, 2018
Other current assets:
Income taxes receivable	$	11.6	$	19.7
Other long-term assets:
Income taxes receivable	$	—	$	—
Accrued expenses:
Income taxes payable	$	3.5	$	8.6

Net Operating Loss and Tax Credit Carryforwards

Operating loss and tax credit carryforwards expire as follows:



Fiscal Year Ending February	Net Operating Loss Carryforwards (Gross)						Net Operating Loss Carryforwards (Tax Effected)											Tax Credit Carryforwards
Fiscal Year Ending February	Federal		State		International		Federal		State			International			Total			Tax Credit Carryforwards
2020	$	—	$	—	$	0.4	$	—	$	—		$	0.1		$	0.1		$	—
2023-2038	1.0		14.1		—		0.2		1.6			—			1.8			38.7
No expiration	—		—		185.2		—		—			44.6			44.6			—
	$	1.0	$	14.1	$	185.6	0.2		1.6			44.7			46.5			38.7
Valuation allowances							—		(0.6		)	(5.8		)	(6.4		)	(1.5		)
Net benefit							$	0.2	$	1.0		$	38.9		$	40.1		$	37.2

Future tax benefits for net operating loss and tax credit carryforwards are recognized to the extent that realization of these benefits is considered more likely than not. It is considered more likely than not that a benefit of $77.3 will be realized on these net operating loss and tax credit carryforwards. This determination is based on the expectation that related operations will be sufficiently profitable or various tax, business and other planning strategies available to us will enable utilization of the carryforwards. We assess the available positive and negative evidence to estimate if sufficient future taxable income will be generated to utilize the existing deferred tax assets. Valuation allowances are recorded to the extent realization of these carryovers is not more likely than not.

Uncertain Tax Positions

We are subject to taxation in the U.S. and various states and foreign jurisdictions with varying statutes of limitation. Tax years that remain subject to examination by major tax jurisdictions include: the U.S. 2019, Canada 2016 through 2019, France 2015 through 2019 and Germany 2014 through 2019. We adjust these reserves, as well as the related interest and penalties, in light of changing facts and circumstances.

We are audited by the U.S. Internal Revenue Service under the Compliance Assurance Process (“CAP”). Under CAP, the U.S. Internal Revenue Service works with large business taxpayers to identify and resolve issues prior to the filing of a tax return. Accordingly, we record minimal liabilities for U.S. federal uncertain tax positions.

We recognize interest and penalties associated with uncertain tax positions in income tax expense, and these items were insignificant for 2019, 2018 and 2017.

A reconciliation of the beginning and ending balances of unrecognized tax benefits is as follows:



Unrecognized Tax Benefits	Year Ended
Unrecognized Tax Benefits	February 22, 2019			February 23, 2018			February 24, 2017
Balance as of beginning of period	$	2.2		$	2.8		$	8.6
Gross decreases—tax positions in prior period	—			(1.0		)	(5.3		)
Currency translation adjustment	(0.2		)	0.4			(0.5		)
Balance as of end of period	$	2.0		$	2.2		$	2.8

We have taken tax positions in a non-U.S. jurisdiction that do not meet the more likely than not test required under the uncertain tax position accounting guidance. Since the tax positions have increased net operating loss carryforwards, the underlying deferred tax asset is shown net of a $2.0 liability for uncertain tax positions as of February 22, 2019 and a $2.2 liability as of February 23, 2018. No other amounts are recorded as a liability for uncertain tax positions, including interest and penalties, on the Consolidated Balance Sheets.

Unrecognized tax benefits of $2.0, if favorably resolved, would be recorded as an income tax benefit. We do not expect the amount of unrecognized tax benefits will significantly change due to expiring statutes or audit activity in the next twelve months.