

	Two Quarters Ended			Fiscal Years Ended
	January 3, 2020			June 28, 2019			June 29, 2018			June 30, 2017

	(In millions)
Current:
United States	$	11		$	105		$	(141	)	$	117
International	37			9			12			9
State and local	16			8			(11		)	6
	64			122			(140		)	132
Deferred:
United States	33			15			324			121
International	(15		)	(3		)	(3		)	1
State and local	(9		)	26			25			7
	9			38			346			129
	$	73		$	160		$	206		$	261



	Two Quarters Ended		Fiscal Years Ended
	January 3, 2020		June 28, 2019			June 29, 2018			June 30, 2017

	(In millions)
Continuing operations	$	73	$	160		$	206		$	261
Discontinued operations	—		(1		)	(5		)	(110		)
Total income tax provision	$	73	$	159		$	201		$	151



	Two Quarters Ended		Fiscal Years Ended
	January 3, 2020		June 28, 2019		June 29, 2018		June 30, 2017
U.S. statutory income tax rate	21.0	%	21.0	%	28.1	%	35.0	%
State taxes	1.4		2.4		1.9		1.0
International income	0.9		(0.5	)	(0.5	)	(1.3	)
Research and development tax credit	(4.7	)	(4.5	)	(2.9	)	(2.0	)
Foreign derived intangibles income deduction	(0.8	)	(1.3	)	—		—
Change in valuation allowance	(4.8	)	(1.8	)	0.2		(0.2	)
U.S. production activity benefit	—		—		(0.9	)	(0.5	)
Equity-based compensation⁽¹⁾	(5.4	)	(2.1	)	(1.8	)	(2.6	)
Settlement of tax audits	—		—		(2.2	)	—
U.S. tax reform	—		—		0.4		—
Other items	0.4		1.2		0.4		(0.1	)
Effective income tax rate	8.0	%	14.4	%	22.7	%	29.3	%

As of January 3, 2020, we estimate our outside basis difference in foreign subsidiaries that are considered indefinitely reinvested to be approximately $4 billion. The outside basis difference is comprised predominantly of purchase accounting adjustments and to a lesser extent, undistributed earnings and other equity adjustments. In the event of a disposition of the foreign subsidiaries or a distribution, we may be subject to incremental U.S. income taxes, subject to an adjustment for foreign tax credits, and withholding taxes or income taxes payable to the foreign jurisdictions. As of January 3, 2020, the determination of the amount of unrecognized deferred tax liability related to the outside basis difference is not practicable.

On December 22, 2017, the Tax Cuts and Jobs Act of 2017 (the “Tax Act”) was signed into U.S. law. Among other provisions, the Tax Act reduced the U.S. statutory corporate income tax rate from a maximum 35 percent to a flat 21 percent, effective January 1, 2018. Based on our fiscal year end, our blended U.S. statutory corporate income tax rate for fiscal 2018 was 28.1 percent. This drop in the tax rate resulted in a one-time benefit of $26 million ($.21 per diluted share) at the date of enactment. Additionally, we recognized expense of $8 million in fiscal 2018 to revalue our existing net deferred income tax balances.

During the second quarter of fiscal 2019, we completed our accounting for the income tax impact of enactment of the Tax Act and there were no material changes from the estimates reported in our Current Report on Form 8-K filed with the SEC on December 13, 2018.

The implementation of a modified territorial tax system under the Tax Act subjects us to tax on our Global Intangible Low-Taxed Income (“GILTI”) starting with fiscal 2019. The Financial Accounting Standards Board has permitted companies to make an accounting policy decision to either (1) treat taxes due on future GILTI inclusions in U.S. taxable income as a current-period expense when incurred (“period cost method”) or (2) factor such amounts into the measurement of its deferred taxes (“deferred method”). We have elected to use the period cost method.



	January 3, 2020			June 28, 2019			June 29, 2018

	(In millions)
Deferred tax assets:
Accruals	$	240		$	152		$	178
Tax loss and credit carryforwards	177			92			119
Share-based compensation	27			28			26
Capital loss carryforwards	44			95			101
Pension and other post-employment benefits	431			305			188
Operating lease obligation	213			—			—
Other	238			75			64
Valuation allowance⁽¹⁾	(185		)	(159		)	(181		)
Deferred tax assets, net	1,185			588			495

Deferred tax liabilities:
Property, plant and equipment	(159		)	(71		)	(65		)
Unbilled receivables	(51		)	(65		)	(86		)
Acquired intangibles	(2,037		)	(260		)	(268		)
Operating lease right-of-use asset	(196		)	—			—
Other	(121		)	(31		)	(36		)
Deferred tax liabilities	(2,564		)	(427		)	(455		)
Net deferred tax assets (liabilities)	$	(1,379	)	$	161		$	40

Net deferred tax assets (liabilities) were classified as follows in our Consolidated Balance Sheet:



	January 3, 2020			June 28, 2019			June 29, 2018

	(In millions)
Non-current deferred income tax assets	$	102		$	173		$	119
Non-current deferred income tax liabilities	(1,481		)	(12		)	(79		)
	$	(1,379	)	$	161		$	40

Tax loss and credit carryforwards at January 3, 2020 have expiration dates ranging from less than one year and no expiration in certain instances. The tax-effected amounts of federal, international, and state and local operating loss carryforwards at January 3, 2020 were $8 million, $46 million and $28 million, respectively. The tax-effected amounts of federal and state and local capital loss carryforwards at January 3, 2020 were $24 million and $21 million, respectively. The amounts of federal, international, and state and local credit carryforwards at January 3, 2020 were $6 million, $14 million and $78 million, respectively

Income from continuing operations before income taxes of international subsidiaries was $96 million in the two quarters ended January 3, 2020. Income from continuing operations before income taxes of international subsidiaries was $37 million, $43 million and $42 million in fiscal 2019, 2018 and 2017, respectively. We received $8 million in income tax refunds, net of income taxes paid, in the two quarters ended January 3, 2020; paid $137 million in income tax, net of refunds received, in fiscal 2019; received $8 million in income tax refunds, net of income taxes paid, in fiscal 2018; and paid $51 million, net of refunds received, in fiscal 2017.



	Two Quarters Ended			Fiscal Years Ended
	January 3, 2020			June 28, 2019			June 29, 2018			June 30, 2017

	(In millions)
Balance at beginning of period	$	204		$	102		$	90		$	63
Additions based on tax positions taken during current period	35			31			17			52
Additions based on tax positions taken during prior periods	—			80			23			—
Additions for tax positions related to acquired entities	226			—			—			—
Decreases based on tax positions taken during prior periods	(7		)	(9		)	(28		)	(25		)
Decreases from lapse in statutes of limitations	(20		)	—			—			—
Balance at end of period	$	438		$	204		$	102		$	90

As of January 3, 2020, we had $438 million of unrecognized tax benefits, of which $313 million would favorably impact our future tax rates in the event that the tax benefits are eventually recognized. As of June 28, 2019, we had $204 million of unrecognized tax benefits, of which $162 million would favorably impact our future tax rates in the event that the tax benefits are eventually recognized. As of June 29, 2018, we had $102 million of unrecognized tax benefits, of which $92 million would favorably impact our future tax rates in the event that the tax benefits are eventually recognized.

We recognize accrued interest and penalties related to unrecognized tax benefits as part of our income tax expense. We had accrued $31 million for the potential payment of interest and penalties as of January 3, 2020 (and this amount was not included in the $438 million of unrecognized tax benefits balance at January 3, 2020 shown above). We had accrued $3 million for the potential payment of interest and penalties as of June 28, 2019 (and this amount was not included in the $204 million of unrecognized tax benefits balance at June 28, 2019 shown above). We had accrued $4 million for the potential payment of interest and penalties as of June 29, 2018 (and this amount was not included in the $102 million of unrecognized tax benefits balance at June 29, 2018 shown above).

We file numerous separate and consolidated income tax returns reporting our financial results and, where appropriate, those of our subsidiaries and affiliates, in the U.S. Federal jurisdiction and various state, local and foreign jurisdictions. Pursuant to the Compliance Assurance Process, the IRS is examining the Harris federal tax returns for fiscal 2017 and 2018 and refund claims related to fiscal 2010 through 2016. In addition, legacy L3’s federal tax returns for calendar years 2017 and 2018 and refund claims related to calendar years 2015 and 2016 are currently under IRS examination.

The Canadian Revenue Agency is currently examining our returns for fiscal 2014 through fiscal 2016, and we are still negotiating the provincial portions of a Canadian assessment relating to fiscal 2000 through fiscal 2006. We are currently under examination or contesting proposed adjustments by various state and international tax authorities for fiscal years ranging from 2010 through 2018. It is reasonably possible that there could be a significant decrease or increase to our unrecognized tax benefit balance during the course of the next twelve months as these examinations continue, other tax examinations commence or various statutes of limitations expire. An estimate of the range of possible changes cannot be made for remaining unrecognized tax benefits because of the significant number of jurisdictions in which we do business and the number of open tax periods.