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Income Tax
3 Months Ended
Mar. 27, 2020
Income Tax Disclosure [Abstract]  
Income Tax

7. INCOME TAX

The Company’s income tax provision and effective tax rate for the three months ended March 27, 2020 were $4.5 million and 29.8%, respectively. The Company’s income tax provision and effective tax rate for the three months ended March 29, 2019 were $1. 5 million and 52.7%, respectively. The change in respective rates reflects, primarily, changes in the geographic mix of worldwide earnings and financial results in jurisdictions which are taxed at different rates and the impact of losses in jurisdictions with full federal and state valuation allowances.  

Company management continuously evaluates the need for a valuation allowance and, as of March 27, 2020, concluded that a full valuation allowance on its federal and state deferred tax assets was still appropriate.

 

The Company provides for U.S. income taxes on its undistributed earnings of foreign subsidiaries as required by the Tax Act Cuts and Jobs (TCJA). However, the Company does not provide for any withholding taxes on its undistributed earnings of its subsidiaries that it intends to invest indefinitely outside the U.S. In prior years, the Company determined that a portion of the current year earnings of one of its China subsidiaries may be remitted in the future to one of its foreign subsidiaries outside of China and, accordingly, the Company provided for the related withholding taxes in its Condensed Consolidated Financial Statements. The Company remitted a portion of those earnings during 2019 and may remit the remainder of the earnings in which withholding taxes have already been accrued but does not currently expect to remit any other Chinese earnings. The Company has also historically remitted earnings from its Singapore subsidiary and may do so again in the future. However, the Company has not accrued any withholding taxes on Singapore earnings as the country does not impose a withholding tax. If the Company changes its intent to reinvest its undistributed foreign earnings indefinitely or if a greater amount of undistributed earnings are needed than the previous anticipated remaining unremitted foreign earnings, the Company could be required to accrue or pay foreign taxes on some or all of these undistributed earnings. As of March 27, 2020, the Company had undistributed earnings of foreign subsidiaries that are indefinitely invested outside of the U.S. of approximately $241.6 million. It is not practicable to determine the tax liability that might be incurred if these earnings were to be distributed.

 

As of March 27, 2020 and March 29, 2019, the Company’s gross liability for unrecognized tax benefits, excluding interest, was $1.0 million for both periods. Although it is possible, that some of the unrecognized tax benefits could be settled within the next twelve months, the Company cannot reasonably estimate the outcome at this time.

 

On March 27, 2020, the Coronavirus Aid, Relief and Economic Security (“CARES”) Act was enacted and signed into law and GAAP requires recognition of the tax effects of new legislation during the reporting period that includes the enactment date.  The CARES Act includes changes to the tax provisions that benefits business entities and makes certain technical corrections to the 2017 TCJA. The tax relief measures for businesses include a five-year net operating loss carryback, suspension of annual deduction limitation of 80% of taxable income from net operating losses generated in a tax year beginning after December 31, 2017, changes in the deductibility of interest, acceleration of alternative minimum tax credit refunds, payroll tax relief, and a technical correction to allow accelerated deductions for qualified improvement property. The Act also provides other non-tax benefits to assist those impacted by the pandemic. The Company evaluated the impact of the CARES Act and determined that there was no significant impact to the income tax provision for the quarter.