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Income Taxes
6 Months Ended
Oct. 30, 2020
Income Tax Disclosure [Abstract]  
Income Taxes Income Taxes
The Company's effective tax rate for the three and six months ended October 30, 2020 was 5.9 percent and 11.2 percent, respectively, as compared to (6.0) percent and 1.0 percent for the three and six months ended October 25, 2019, respectively. The increase in the effective tax rate for the three and six months ended October 30, 2020, as compared to the corresponding periods in the prior fiscal year, was primarily due to the impact of certain tax adjustments and year-over-year changes in operational results by jurisdiction.
Certain Tax Adjustments
During the three months ended October 30, 2020, the cost from certain tax adjustments of $16 million, recognized in income tax provision (benefit) in the consolidated statements of income, included a cost of $16 million associated with the amortization of the previously established deferred tax assets from intercompany intellectual property transactions.
During the six months ended October 30, 2020, the net cost from certain tax adjustments of $20 million, recognized in income tax provision (benefit) in the consolidated statements of income, included the following:
A benefit of $3 million associated with the finalization of an intercompany sale of intellectual property and the establishment of a deferred tax asset. The cumulative amount of deferred tax benefit previously recognized from intercompany intellectual property transactions and recorded as Certain Tax Adjustments is $1.5 billion. The corresponding deferred tax assets will be amortized over a period of approximately 20 years.
A cost of $23 million associated with the amortization of the previously established deferred tax assets from intercompany intellectual property transactions.
During the three months ended October 25, 2019, the benefit from certain tax adjustments of $251 million, recognized in income tax provision (benefit) in the consolidated statements of income, included a benefit of $251 million related to tax legislative changes in Switzerland which abolished certain preferential tax regimes the Company benefited from and replaced them with a new set of internationally accepted measures. The legislation provided for higher effective tax rates but allowed for a transitional period whereby an amortizable asset was created for Swiss federal income tax purposes which will be amortized and deducted over a 10-year period.
During the six months ended October 25, 2019, the net benefit from certain tax adjustments of $281 million, recognized in income tax provision (benefit) in the consolidated statements of income, included the following:
A net benefit of $30 million related to U.S. Treasury’s issuance of certain Final Regulations associated with U.S. Tax Reform. The primary impact of these regulations resulted in the re-establishment of our permanently reinvested assertion on certain foreign earnings and reversing the previously accrued tax liability. This benefit was partially offset by additional tax associated with a previously executed internal reorganization of certain foreign subsidiaries.
A benefit of $251 million related to tax legislative changes in Switzerland which abolished certain preferential tax regimes the Company benefited from and replaced them with a new set of internationally accepted measures. The legislation provided for higher effective tax rates but allowed for a transitional period whereby an amortizable asset was created for Swiss federal income tax purposes which will be amortized and deducted over a 10-year period.
At both October 30, 2020 and April 24, 2020, the Company's gross unrecognized tax benefits were $1.9 billion. In addition, the Company had accrued gross interest and penalties of $251 million at October 30, 2020. If all the Company’s unrecognized tax benefits were recognized, approximately $1.8 billion would impact the Company’s effective tax rate. At October 30, 2020 and April 24, 2020, the amount of the Company's gross unrecognized tax benefits recorded as a noncurrent liability within accrued income taxes on the consolidated balance sheets was $940 million and $911 million, respectively. The Company recognizes interest and penalties related to income tax matters within income tax provision (benefit) in the consolidated statements of income and records the liability within either current or noncurrent accrued income taxes on the consolidated balance sheets.
Refer to Note 16 to the consolidated financial statements for additional information regarding the status of current tax audits and proceedings.