Income (loss) before provision for income taxes on the accompanying statements of operations and comprehensive loss included the following components (in thousands):

	Years Ended June 30,
	2020			2019			2018
Domestic	$	(1,811	)	$	(23,799	)	$	(30,747	)
Foreign		7,501			9,455			7,726
Total worldwide	$	5,690		$	(14,344	)	$	(23,021	)

	Years Ended June 30,
	2020		2019			2018
Current:
Federal	$	—	$	—		$	—
State		15		32			63
Foreign		1,495		2,140			785
Total current	$	1,510	$	2,172		$	848
Deferred:
Federal		—		—			—
State		—		—			—
Foreign		353		(86	)		30
Total deferred		353		(86	)		30
Total provision for income taxes	$	1,863	$	2,086		$	878

Income tax payable was $0.8 million, $1.6 million and $1.1 million at June 30, 2020, 2019 and 2018, respectively. A reconciliation of income taxes at the statutory federal income tax rate to the provision for income taxes included in the accompanying consolidated statements of operations and comprehensive loss is as follows (in thousands):

	Years Ended June 30,
	2020			2019			2018
U.S. federal taxes (benefit):
At federal statutory rate	$	1,195		$	(3,012	)	$	(6,446	)
State tax, net of federal benefit		15			32			63
Share-based compensation expense		810			1,128			1,712
Debt extinguishment		—			—			967
Other non-deductible permanent items		418			486			702
R&D credits		(635	)		(877	)		(142	)
Foreign taxes		273			(38	)		(1,295	)
Other		(69	)		58			(228	)
Transition Tax		—			—			3,348
Tax Cuts and Jobs Act		—			—			54,072
Global Intangible Low-Taxed Income		1,185			1,924			—
Change in valuation allowance		(1,329	)		2,385			(51,875	)
Total	$	1,863		$	2,086		$	878

Deferred income taxes reflect the net 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 the Company’s net deferred tax assets were as follows (in thousands):

	June 30,
	2020			2019
Deferred tax assets:
Federal and state net operating losses	$	75,615		$	77,228
Accrued expenses and reserves		4,972			7,497
Lease liability		5,366			—
Deferred revenue		5,038			2,897
R&D Credits		22,843			22,108
Share-based compensation expense		1,337			1,327
Capitalized research and development		2,683			3,343
Unicap		2,105			1,953
Fixed assets/intangibles		1,199			1,323
Section 163(j) interest		1,823			1,857
Other		1,290			1,582
Total deferred tax assets		124,271			121,115
Deferred tax liabilities:
Contract acquisition costs		(977	)		(1,146	)
Right of use assets		(4,508	)		—
Total deferred tax liabilities		(5,485	)		(1,146	)
Valuation allowance		(118,300	)		(119,125	)
Net deferred tax assets	$	486		$	844

As of June 30, 2020, the Company had approximately $322.1 million and $139.1 million in federal and state net operating loss carryforwards, respectively. The federal and state carryforwards expire in varying amounts beginning in 2025 for federal and 2021 for state purposes.

In addition, as of June 30, 2020, the Company had federal and state research and development tax credits of approximately $22.0 million and $20.4 million, respectively. If not utilized, the federal research credits will begin to expire in 2021, the California research credits have no expiration date, and the other state research credits will begin to expire in 2021.

Under the Internal Revenue Code (“IRC”) Sections 382 and 383, annual use of our net operating loss and research tax credit carryforwards to offset taxable income may be limited based on cumulative changes in ownership. Although ownership changes have occurred in the past, the carryovers should be available for utilization by the Company before they expire, provided the Company generates sufficient future taxable income. There were no equity financings in the current fiscal year that would result in an ownership change under Section 382. The Company will continue to monitor the changes in equity that would affect the tax attributes as reported.

Based on the available objective evidence and history of losses, the Company has established a 100% valuation allowance against the combined domestic net deferred tax assets of Accuray and TomoTherapy because of uncertainty surrounding the realization of such deferred tax assets.

In December 2017, the Tax Cuts and Jobs Act of 2017 (Tax Act) was signed into law which significantly amends the Internal Revenue Code of 1986, among other things reduces the corporate tax rate from a top marginal rate of 35% to a flat rate of 21%, imposes a one-time tax on offshore earnings at reduced rates regardless of whether they are repatriated. The Tax Act did not impact the Company's financial statements due to the Company's historical U.S. losses.

In March 2020, the Coronavirus Aid, Relief and Economic Security Act (the "CARES Act") was signed into law in the United States. The provisions of the CARES Act did not have a material impact on the Company’s effective tax rate and consolidated financial statements given the Company's full valuation allowance against its net U.S. deferred tax assets.

Beginning fiscal year 2019, for U.S. federal tax purposes certain income earned by controlled foreign corporations (“CFCs”) must be included currently in the gross income of the CFC’s U.S. shareholder. The income required to be included in gross income is referred to as global intangible low tax income (“GILTI”) and is defined under IRC Section 951A as the excess of the shareholder’s net CFC tested income over the net deemed tangible income return. The GILTI inclusion amount has been absorbed by net operating losses. The Company has made a policy decision to record GILTI tax as a current-period expense when incurred.

The Tax Act also enacted the Base Erosion and Anti-Abuse Tax (“BEAT”). The BEAT minimum tax under IRC Section 59A is applicable to the extent that the BEAT tax amount is greater than the regular corporate tax for a given year. This tax is applicable to companies with prior 3-year average annual gross receipts exceeding $500 million. The Company does not currently meet this threshold since its current average annual gross receipts is less than $500 million.

The Company continues to permanently re-invest its $45.2 million undistributed earnings of its foreign subsidiaries outside the U.S. Future repatriation of the Company's foreign earnings are subject to income tax withholdings. Any potential deferred tax liability would net with the Company’s valuation allowance.

The aggregate changes in the balance of gross unrecognized tax benefits were as follows (in thousands):

	Years Ended June 30,
	2020			2019			2018
Balance at beginning of year	$	16,280		$	15,299		$	15,819
Tax positions related to current year:
Additions		954			934			823
Tax positions related to prior years:
Additions		286			580			—
Reductions		(524	)		(533	)		(1,343	)
Balance at end of year	$	16,996		$	16,280		$	15,299

The calculation of unrecognized tax benefits involves dealing with uncertainties in the application of complex global tax regulations. Management regularly assesses the Company’s tax positions with respect to legislative, bilateral tax treaty, regulatory and judicial developments in the countries in which the Company does business. The reduction in prior year’s tax positions primarily relates to lapses of applicable statutes of limitations. The Company anticipates that except for $0.01 million in uncertain tax positions that may be reduced related to the lapse of various statutes of limitation, there will be no material changes in uncertain tax positions in the next 12 months. As of June 30, 2020, the amount of gross unrecognized tax benefits was $17.0 million of which $16.8 million would not affect income tax expense before consideration of any valuation allowance.

The Company’s practice is to recognize interest and/or penalties related to income tax matters in income tax expense. As of June 30, 2020 and 2019, the Company had approximately $0.01 million and $0.06 million, respectively, of accrued interest and penalties related to uncertain tax positions.

The Company files income tax returns in the United States federal, various states and foreign jurisdictions. Due to tax attributes being carried forward and utilized during open years, the statute of limitations remains open for the U.S. federal jurisdiction and domestic states for tax years from 2000 and forward. The statutes of limitation with respect to the foreign jurisdictions where the Company files income tax returns vary from jurisdiction to jurisdiction and range from 3 to 10 years, and the material foreign jurisdictions are France, Switzerland, and Japan.

The Company is also subject to examination of its income tax returns by the Internal Revenue Service (IRS) and other foreign tax authorities, and in some cases the Company has received additional tax assessments which have not been significant.