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Income Taxes
9 Months Ended
Dec. 29, 2018
Income Tax Disclosure [Abstract]  
Income Taxes

10. Income Taxes

 

The Company files income tax returns in the U.S. federal jurisdiction and various states and foreign jurisdictions. With few exceptions, the Company is no longer subject to state or foreign income tax examinations by tax authorities for years ending before April 2, 2005. The Company is no longer subject to U.S. federal tax examination by the Internal Revenue Service for years ending before March 29, 2015. A U.S. federal tax examination by the Internal Revenue Service for the year ended March 30, 2013 was effectively settled in fiscal 2016.

 

The effective income tax rates for the three month periods ended December 29, 2018 and December 30, 2017, were 15.0% and 23.9%. The reduction in the effective income tax rate for the three months ended December 29, 2018 as compared with the prior year period reflects the net benefits of the Tax Cut and Jobs Act (“TCJA” or “the Act”), which reduced the U.S. statutory rate from 35% to 21% for tax years beginning in 2018 and made other changes to the U.S. federal income tax laws affecting both domestic and foreign income. The reduction in the effective income tax rate includes a benefit associated with the sale of the Miami division, a tax benefit associated with the decrease in the Company’s unrecognized tax positions related to the statute of limitations expiration, and a benefit associated with share-based compensation. The effective tax rate was also increased by a tax expense associated with withholding tax on a one-time repatriation of cash from the Company’s foreign operations during the three months ended December 29, 2018.

 

 The TCJA was signed into law on December 22, 2017 revising the U.S. corporate income tax. Changes included, but were not limited to, the reduction of the U.S. federal corporate rate from 35% to 21%, the elimination of certain deductions and imposing one-time net charge related to the taxation of undistributed foreign earnings. Also on December 22, 2017, the SEC issued Staff Accounting Bulletin No. 118 (“SAB 118”) to address the application of U.S. GAAP in situations where a registrant does not have the necessary information available, prepared or analyzed in reasonable detail to complete the accounting for certain income tax effects of the Act. SAB 118 allowed companies to record provisional estimates during a measurement period not extending beyond one year from the TCJA enactment date.

 

For the year ended March 31, 2018 the Company recognized as components of income tax expense $9,166 for the one-time net charge related to the taxation of undistributed foreign earnings and $9,318 tax benefit related to the remeasurement of U.S. deferred tax balances to reflect the new U.S. corporate income tax rate. As of December 22, 2018, we have completed the accounting for all impacts of the TCJA and there have been no changes to previously recorded amounts.

 

No additional income tax provision has been made on any remaining undistributed foreign earnings not subject to the one-time net charge related to the taxation of unremitted foreign earnings or any additional outside basis difference as these amounts continue to be indefinitely reinvested in foreign operations.

 

One of the international tax law changes provided for with the TCJA relates to the taxation of a corporation’s global intangible low-taxed income (“GILTI”) for tax years beginning after December 31, 2017. The Company has evaluated this provision of the TCJA and the application of ASC 740, and does not believe that GILTI will have a significant impact.

 

An additional tax law change provided under the TCJA introduced new rules for the treatment of certain foreign income, including foreign derived intangible income (“FDII”) for tax years beginning after December 31, 2017. The Company has evaluated this provision of the TCJA and believes the FDII results in a favorable impact on the application of ASC 740.

 

In addition to discrete items, the effective income tax rates for these periods are different from the U.S. statutory rates due to a special U.S. manufacturing deduction (fiscal 2018 only), the U.S. credit for increasing research activities which decrease the rate, and state income taxes which increases the rate.

 

The effective income tax rate for the three-month period ended December 29, 2018 of 15.0% includes $4,048 of tax benefit associated with the sale of the Miami division. The third quarter provision was also impacted by $1,469 of tax benefit associated with the decrease in the Company’s unrecognized tax positions, pertaining primarily to the statute of limitations expiration of items associated with the consolidation and restructuring of the Company’s U.K. manufacturing facility. The third quarter provision also includes $943 tax expense associated with withholding tax on a one-time repatriation of cash from the Company’s foreign operations and $558 of tax benefits associated with share-based compensation. The effective income tax rate without discrete items for the three-month period ended December 29, 2018 would have been 22.3%. The effective income tax rate for the three-month period ended December 30, 2017 of 23.9% was impacted by one-time adjustments associated with the enactment of the TCJA. Included in these adjustments was an estimated charge of $9,491 associated with the repatriation transition tax and an estimated benefit of $8,708 associated with the revaluation of our deferred tax liabilities. The TCJA also impacted the third quarter provision with a benefit from the lower blended statutory tax rate of 31.5% and by $1,238 of tax benefit associated with share-based compensation. The effective income tax rate without discrete items for the three-month period ended December 30, 2017 would have been 25.3%. The Company believes it is reasonably possible that some of its unrecognized tax positions may be effectively settled within the next twelve months due to the closing of audits and the statute of limitations expiring in varying jurisdictions. The decrease in the Company’s unrecognized tax positions, pertaining primarily to credits and state tax, is estimated to be approximately $356.

 

The effective income tax rate for the nine-month period ended December 29, 2018 of 14.6% includes a benefit of $4,048 million associated with the sale of the Miami division. The effective tax rate was also impacted by $1,510 of tax benefit associated with the decrease of the Company’s unrecognized tax positions, pertaining primarily to the consolidation and restructuring of the Company’s U.K. manufacturing facility. The effective rate was also impacted by $943 of tax expense associated with withholding tax on a one-time repatriation of cash from the Company’s foreign operations and $5,063 associated with share-based compensation. The effective income tax rate without this benefit and other items for the nine-month period ended December 29, 2018 would have been 21.6%. The effective income tax rate for the nine-month period ended December 30, 2017 of 28.0% was impacted by one-time adjustments associated with the enactment of the TCJA. These adjustments were mainly comprised of a charge of $9,491 for the repatriation transition tax and a benefit of $8,708 associated with the revaluation of our deferred tax liabilities. The effective income tax rate also benefited from a lower blended statutory tax rate of 31.5% as a result of the enactment of the TCJA and $3,916 tax benefit associated with share-based compensation. The effective income tax rate without discrete items for the three-month period ended December 30, 2017 would have been 33.0%.