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Income Taxes
6 Months Ended
Sep. 30, 2019
Income Tax Disclosure [Abstract]  
Income Taxes
Income Taxes
Income tax provision
Income/(loss) before income taxes and the income tax provision/(benefit) include the following (in thousands):
 
Fiscal Year Ended March 31,
2017
 
2018
 
2019
Domestic
$
(58,188
)
 
$
(64,391
)
 
$
(163,385
)
Foreign
41,795

 
12,616

 
23,474

Total
$
(16,393
)
 
$
(51,775
)
 
$
(139,911
)

The income tax provision includes the following (in thousands):
 
Fiscal Year Ended March 31,
2017
 
2018
 
2019
Income tax (benefit) expense
 
 
 
 
 
Federal
$
2,048

 
$
(393
)
 
$
3,213

State
605

 
1,198

 
575

Foreign
8,585

 
11,638

 
5,920

Total current tax position
11,238

 
12,443

 
9,708

Federal
(23,781
)
 
(72,336
)
 
(29,021
)
State
(4,404
)
 
(990
)
 
(5,464
)
Foreign
(242
)
 
(114
)
 
1,060

Total deferred tax provision
(28,427
)
 
(73,440
)
 
(33,425
)
Total income tax (benefit) expense
$
(17,189
)
 
$
(60,997
)
 
$
(23,717
)

The Company’s income tax benefit of $17.2 million for the year ended March 31, 2017 differed from the amount computed on pre-tax loss at the U.S. federal income tax rate of 35%, because tax attributes at the Company are shared with other members of its consolidated tax group, some of whom are not included in this filing.
The Company’s income tax benefit of $61.0 million for the year ended March 31, 2018 differed from the amount computed on pretax income at the U.S. federal blended rate of 31.5% primarily due to the Tax Cuts and Jobs Act (the “Tax Act”). The Tax Act was signed into law on December 22, 2017 and includes, among other items, a permanent reduction to the U.S. corporate income tax rate from 35% to 21% effective January 1, 2018 and requires immediate taxation of accumulated, unremitted non-U.S. earnings (the “Transition Tax”). As a result, at March 31, 2018, the Company recognized a tax benefit of
$50.0 million from revaluing U.S. net deferred tax liabilities. The Transition Tax had no impact on the Company’s income tax provision.
The Company’s income tax benefit of $23.7 million for the year ended March 31, 2019 differed from the amount computed on pre-tax loss at the U.S. federal income tax rate of 21% primarily because of non-deductible share-based compensation. The Tax Act includes two new U.S. corporate tax provisions effective for the year ended March 31, 2019, the global intangible low-taxed income (“GILTI”) and the base-erosion and anti-abuse tax (“BEAT”). The GILTI provision requires the Company to include in its U.S. income tax return non-U.S. subsidiary earnings in excess of an allowable return on the non-U.S. subsidiary’s tangible assets. The BEAT provision in the Tax Act eliminates the deduction of certain base-erosion payments made to related non-U.S. corporations, and imposes a minimum tax if the amount is greater than the regular tax. The Company evaluated the GILTI and BEAT provisions resulting in an immaterial impact to the financial statements for the year ended March 31, 2019.
The tax rate reconciliation is as follows (in thousands):
 
Fiscal Year Ended March 31,
2017
 
2018
 
2019
Income tax (benefit) at U.S. federal statutory income tax rate
$
(5,738
)
 
$
(16,309
)
 
$
(29,381
)
State and local tax expense
(3,799
)
 
208

 
(4,890
)
Foreign tax rate differential
(2,920
)
 
3,619

 
2,051

Non-deductible expenses
1,215

 
8,645

 
11,807

Tax credits
(7,482
)
 
(6,173
)
 
(13,233
)
Sharing of consolidated tax attributes
(6,417
)
 
(8,890
)
 

Changes in tax law

 
(50,033
)
 

Changes in valuation allowance
6,633

 
5,133

 
6,087

Foreign withholding tax
1,544

 
2,701

 
3,086

Other adjustments
(225
)
 
102

 
756

Total income tax (benefit)
$
(17,189
)
 
$
(60,997
)
 
$
(23,717
)

Deferred tax assets and liabilities
Based on the Company’s review of both positive and negative evidence regarding the realizability of deferred tax assets at March 31, 2019, a valuation allowance continues to be recorded against certain deferred tax assets based upon the conclusion that it was more likely than not they would not be realized. The valuation allowance at March 31, 2018 and 2019 relates primarily to foreign tax credits and net operating losses.
Temporary differences and carryforwards that give rise to a significant portion of deferred tax assets and liabilities are as follows (in thousands):
 
March 31,
2018
 
2019
Deferred revenue
$

 
$
4,752

Intangible assets
1,621

 
1,247

Accrued expenses
4,891

 
5,983

Share-based compensation
714

 
4,776

Net operating loss carryforwards
5,743

 
4,470

Other tax carryforwards, primarily foreign tax credits
25,811

 
32,630

Other
5,165

 
1,183

Total deferred tax assets before valuation allowance
43,945

 
55,041

Less: valuation allowance
(25,591
)
 
(31,678
)
Net deferred tax assets
18,354

 
23,363

Intangible assets
66,253

 
52,778

Capitalized research and development costs
1,792

 
822

Fixed assets
16

 
(447
)
Deferred revenue
2,246

 

State taxes
10,406

 
6,090

Other
7,986

 
1,040

Total deferred tax liabilities
88,699

 
60,283

Net deferred tax liabilities
$
(70,345
)
 
$
(36,920
)
Long-term deferred tax assets
9,850

 
10,678

Long-term deferred tax liabilities
(80,195
)
 
(47,598
)
Net deferred tax liabilities
$
(70,345
)
 
$
(36,920
)

At March 31, 2018 and 2019, the Company had net operating losses (tax-effected) and tax credit carryforwards for income tax purposes before valuation allowance of $31.6 million, and $37.1 million, respectively, that expire in the tax years as follows (in thousands):
 
Fiscal Year Ended March 31,
 
 
2018
 
2019
 
Expiration
Non-U.S. net operating losses
$
4,756

 
$
4,301

 
Indefinite
Non-U.S. net operating losses
988

 
169

 
2020-2026
U.S. federal and state tax carryforwards

 
2,657

 
Indefinite
U.S. federal and state tax carryforwards, primarily foreign tax credits
25,811

 
29,973

 
2026-2037
Total Carryforwards
$
31,555

 
$
37,100

 
 

Uncertain tax positions
The amount of gross unrecognized tax benefits was $9.1 million and $9.7 million as of March 31, 2018 and 2019, respectively, all of which would favorably affect the Company’s effective tax rate if recognized in future periods.
The following is a tabular reconciliation of the total amounts of unrecognized tax benefits for the years ended March 31, 2017, 2018, and 2019 (in thousands):
 
Fiscal Year Ended March 31,
2017
 
2018
 
2019
Gross unrecognized tax benefit, beginning of year
$
8,332

 
$
8,770

 
$
9,143

Gross increases to tax positions for prior periods
461

 
257

 
20

Gross decreases to tax positions for prior periods
(23
)
 
(482
)
 
(70
)
Gross increases to tax positions for current period

 
598

 
560

Gross unrecognized tax benefit, end of year
$
8,770

 
$
9,143

 
$
9,653


As of March 31, 2018 and 2019, the net interest and penalties payable associated with its uncertain tax positions are immaterial. During the years ended March 31, 2017, 2018, and 2019, respectively, the Company recognized an immaterial amount of net interest expense.
The Company has open years from tax periods 2009 and forward, primarily in China. These open years contain matters that could be subject to differing interpretations of applicable tax laws and regulations due to the amount, timing or inclusion of revenue and expenses.
Income Taxes
The Company computes its interim provision for income taxes by applying the estimated annual effective tax rate to loss from operations and adjusts the provision for discrete tax items occurring in the period. The Company’s effective tax rate for the three months ended September 30, 2018 was 10% compared to negative 147% for the three months ended September 30, 2019. The effective tax rate was higher than the U.S. statutory tax rate for the three months ended September 30, 2019 because of the $255.8 million incurred upon the reorganization transactions described in Note 2. The Company’s effective tax rate for the six months ended September 30, 2018 was 11% compared to negative 111% for the six months ended September 30, 2019. The effective tax rate for the six months ended September 30, 2019 was higher than the U.S. federal statutory tax rate primarily because of the reorganization and non-deductible share-based compensation.
Based on the Company’s review of both positive and negative evidence regarding the realizability of deferred tax assets at September 30, 2019, a valuation allowance continues to be recorded against certain deferred tax assets based upon the conclusion that it was more likely than not they would not be realized. The valuation allowance at September 30, 2019 relates primarily to foreign tax credits and net operating losses.
The reorganization triggered a short tax period in the U.S. which gave rise to the acceleration of deferred revenue for tax purposes and a corresponding reduction in the net deferred tax liability during the period of acceleration.
Other matters
The Tax Cuts and Jobs Act (the “Tax Act”) was signed into law on December 22, 2017. The Tax Act changed many aspects of U.S. corporation income taxation and include reduction of the corporate income tax rate from 35% to 21%, implementation of a territorial tax system and imposition of a tax on deemed repatriated earnings of foreign subsidiaries (“Transition Tax”). The Company recognized the tax effects of the Tax Act in the fiscal year ended 2018 and recorded $50.0 million in tax benefit which relates almost entirely to the remeasurement of deferred tax liabilities to the 21% tax rate. The effects of ongoing provisions of the Tax Act, including global intangible low-taxed income (GILTI) and base-erosion and anti-abuse tax (BEAT), are accounted for in the income tax provision.