XML 36 R20.htm IDEA: XBRL DOCUMENT v3.7.0.1
Income Taxes
12 Months Ended
Jul. 01, 2017
Income Tax Disclosure [Abstract]  
Income Taxes
INCOME TAXES
For financial reporting purposes, our income (loss) from continuing operations before income taxes includes the following:
 
Year Ended
 
July 1, 2017
 
July 2, 2016
 
June 27, 2015
 
(Thousands)
Domestic
$
(12,579
)
 
$
(856
)
 
$
(5,725
)
Foreign
115,392

 
10,285

 
(42,181
)
 
$
102,813

 
$
9,429

 
$
(47,906
)

The components of our income tax provision (benefit) are as follows:
 
Year Ended
 
July 1, 2017
 
July 2, 2016
 
June 27, 2015
 
(Thousands)
Current:
 
 
 
 
 
Domestic
$
6

 
$
16

 
$
(5
)
Foreign
629

 
1,023

 
543

Deferred:
 
 
 
 
 
Domestic

 

 

Foreign
(25,681
)
 
(190
)
 
(210
)
 
$
(25,046
)
 
$
849

 
$
328


Reconciliations of our income tax provision (benefit) at the statutory rate to our income tax provision (benefit) are as follows:
 
Year Ended
 
July 1, 2017
 
July 2, 2016
 
June 27, 2015
 
(Thousands)
Tax expense (benefit) at U.S. federal statutory rate
$
34,957

 
$
3,206

 
$
(16,288
)
Tax expense (benefit) at state statutory rate
1,070

 
138

 
(487
)
Other permanent adjustments
2,796

 
1,894

 
1,815

Foreign rate differential
(9,043
)
 
(786
)
 
11,635

Change in valuation allowance
(54,584
)
 
(3,705
)
 
4,165

Other
(242
)
 
102

 
(512
)
Provision for (benefit from) income taxes
$
(25,046
)
 
$
849

 
$
328


We plan to permanently reinvest the unremitted earnings of our non-U.S. subsidiaries except for those subsidiaries where the closure of these subsidiaries is expected to be imminent. We recorded a tax liability of $0.1 million and $0.1 million for the withholding taxes that would be owed upon distribution of these entities' earnings as of July 1, 2017 and July 2, 2016, respectively.
Deferred income taxes reflect the tax effects of temporary differences between the carrying amounts of assets and liabilities for financial reporting purposes and the amounts used for income tax purposes. Significant components of our deferred tax assets and liabilities are as follows:
 
July 1, 2017
 
July 2, 2016
 
(Thousands)
Deferred tax assets:
 
 
 
Net operating loss carryforwards
$
189,620

 
$
216,768

Depreciation and capital losses
25,809

 
27,373

Capitalized research and development
8,531

 
11,579

Inventory valuation
3,234

 
6,656

Accruals and reserves
13,613

 
14,126

Tax credit carryforwards
6,736

 
6,142

Stock-based compensation
2,424

 
1,905

Other asset impairments
1,999

 
2,016

Deferred tax assets
251,966

 
286,565

Valuation allowance
(225,643
)
 
(285,683
)
Total deferred tax assets
26,323

 
882

Deferred tax liabilities:
 
 
 
Acquired intangibles
(454
)
 
(693
)
Withholding tax
(95
)
 
(95
)
Total deferred tax liabilities
(549
)
 
(788
)
Net deferred tax assets
$
25,774

 
$
94


Deferred tax assets and liabilities are determined based on differences between financial reporting and tax bases of assets and liabilities and are measured using the enacted tax rates and laws that will be in effect when the differences are expected to reverse. In evaluating our ability to recover deferred tax assets, we consider all available positive and negative evidence including past operating results, the existence of cumulative losses and our forecast of future taxable income. In determining future taxable income, we are responsible for assumptions utilized including the amount of state, federal and international pre-tax operating income, the reversal of temporary differences and the implementation of feasible and prudent tax planning strategies. These assumptions require significant judgment about the forecasts of future taxable income and are consistent with the plans and estimates we use to manage the underlying businesses.
Recognition of deferred tax assets is appropriate when realization of these assets is more likely than not. Based upon the weight of available evidence, which includes our historical operating performance, the recorded cumulative net losses in prior fiscal periods and the uncertainty of the timing of future profits, we have provided a full valuation allowance against most of our U.S. and foreign deferred tax assets with the exception of our Italy investment tax credit and Japan. Based on a recent history of profitability, firm sales backlog and future income projections, management has released the valuation allowance on all of our Japan subsidiary's deferred tax assets during the fourth quarter of fiscal year 2017. Our valuation allowance decreased by $60.0 million, $44.7 million and $16.6 million for fiscal years 2017, 2016 and 2015, respectively.
We have elected to release both the gross deferred income tax assets and the offsetting valuation allowance pertaining to net operating loss and tax credit carryforwards that represent excess tax benefits from stock-based awards. Recognition of a deferred tax asset for excess tax benefits due to stock-based compensation deductions that have not yet been realized through a reduction in income taxes payable is prohibited. Such unrecognized deferred tax benefits totaled $18.1 million for federal and state as of July 1, 2017, and if and when realized through a reduction in income taxes payable, will be accounted for as a credit to the statement of operations upon the adoption of ASU 2016-09 in the first quarter of fiscal year 2018.
Net operating loss carryforwards by jurisdiction are summarized as follows:
 
July 1, 2017
 
Years of Expiration
 
(Thousands)
 
 
United Kingdom
$
468,436

 
Indefinite
Federal
236,633

 
2018 - 2037
California
166,527

 
2018 - 2037
Japan
44,898

 
2022 - 2026
Other Foreign
1,374

 
2018 -2037
Total
$
917,868

 
 

In addition to our net operating losses, as of July 1, 2017, we had U.S. federal, California, United Kingdom and Canada research and development credits of approximately $0.1 million, $1.0 million, $0.6 million and $2.0 million, respectively. The U.S. federal research credits will expire from 2018 through 2037. The California and United Kingdom research credit may be carried forward indefinitely. The Canada research credit will expire during 2026 if unused. In addition, we have foreign tax credits of approximately $3.1 million, which will expire from 2028 through 2036, and an Italy investment tax credit of $0.1 million.
Utilization of net operating loss carryforwards and credit carryforwards are subject to annual limitations due to ownership changes as provided in the Internal Revenue Code of 1986, as amended, as well as similar state and foreign tax laws. This annual limitation may result in the expiration of a significant portion of the net operating loss carryforwards and tax credits before utilization.
Our total amount of unrecognized tax benefits as of July 1, 2017 was approximately $3.5 million. The total amount of unrecognized tax benefits that, if recognized, would affect the effective tax rate is $2.9 million as of July 1, 2017. While it is often difficult to predict the final outcome of any particular uncertain tax position, management believes that unrecognized tax benefits could decrease by $1.3 million in the next twelve months.
A reconciliation of the beginning balance and the ending balance of gross unrecognized tax benefits, net of interest and penalties, for fiscal year ended July 1, 2017July 2, 2016 and June 27, 2015 is as follows:
 
Year Ended
 
July 1, 2017
 
July 2, 2016
 
June 27, 2015
 
 
 
(Thousands)
 
 
Balance at beginning of period
$
3,779

 
$
4,058

 
$
4,164

Additions for tax positions related to the current year
21

 
639

 
232

Additions for tax positions related to prior years
6

 
538

 
759

Reductions for tax positions related to prior years
(291
)
 
(1,016
)
 
(473
)
Lapse of the applicable statute of limitations

 
(440
)
 
(624
)
Balance at end of period
$
3,515

 
$
3,779

 
$
4,058


We include interest and penalties related to unrecognized tax benefits within the provision for income taxes on our consolidated statements of operations. As of July 1, 2017 and July 2, 2016, we have accrued approximately $0.7 million and $0.7 million for payment of interest and penalties related to unrecognized tax benefits, respectively.
We file U.S. federal, U.S. state and foreign tax returns and have determined that our major tax jurisdictions are the United States, the United Kingdom, Italy, Japan and China. At July 1, 2017, our 2011 to 2017 tax returns were open to potential examination in one or more jurisdictions. In addition, in the U.S. and Japan, any net operating loss and credit carryforwards may extend the ability of the tax authorities to examine our tax returns beyond the regular limits. We are not currently under any U.S. federal, U.S. state, or other foreign tax examinations.