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Income Taxes
12 Months Ended
Oct. 31, 2014
Income Tax Disclosure [Abstract]  
Income Taxes

NOTE 9:  Income Taxes

Income tax expense from continuing operations for each of the fiscal years consisted of:

 

In Thousands

2014

 

 

2013

 

 

2012

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Current

 

 

 

 

 

 

 

 

 

 

 

 

U.S. Federal

$

28,433

 

 

$

27,584

 

 

$

27,999

 

 

State

 

1,790

 

 

 

4,075

 

 

 

196

 

 

Foreign

 

28,944

 

 

 

24,044

 

 

 

20,821

 

 

 

 

59,167

 

 

 

55,703

 

 

 

49,016

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Deferred

 

 

 

 

 

 

 

 

 

 

 

 

U.S. Federal

 

(1,691

)

 

 

(3,105

)

 

 

(2,230

)

 

State

 

(33

)

 

 

(1,592

)

 

 

793

 

 

Foreign

 

(13,169

)

 

 

(17,115

)

 

 

(19,763

)

 

 

 

(14,893

)

 

 

(21,812

)

 

 

(21,200

)

 

Income tax expense

$

44,274

 

 

$

33,891

 

 

$

27,816

 

 

 

U.S. and foreign components of earnings from continuing operations before income taxes for each of the fiscal years were:

 

In Thousands

2014

 

 

2013

 

 

2012

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

U.S.

$

103,339

 

 

$

100,859

 

 

$

97,855

 

 

Foreign

 

107,495

 

 

 

105,756

 

 

 

44,155

 

 

Earnings from continuing operations before income taxes

$

210,834

 

 

$

206,615

 

 

$

142,010

 

 

 

Primary components of the Company’s deferred tax assets (liabilities) at the end of the fiscal years resulted from temporary tax differences associated with the following:

 

In Thousands

 

 

2014

 

 

2013

 

 

 

 

 

 

 

 

 

 

 

 

 

Reserves and liabilities

 

 

$

55,906

 

 

$

60,397

 

 

NOL carryforwards

 

 

 

110

 

 

 

879

 

 

Tax credit carryforwards

 

 

 

31,082

 

 

 

29,862

 

 

Employee benefits

 

 

 

13,086

 

 

 

14,974

 

 

Retirement benefits

 

 

 

10,431

 

 

 

2,759

 

 

Non-qualified stock options

 

 

 

11,063

 

 

 

12,618

 

 

Hedging activities

 

 

 

5,091

 

 

 

-

 

 

Other

 

 

 

856

 

 

 

650

 

 

Total deferred tax assets

 

 

 

127,625

 

 

 

122,139

 

 

 

 

 

 

 

 

 

 

 

 

 

Depreciation and amortization

 

 

 

(15,925

)

 

 

(18,969

)

 

Intangibles and amortization

 

 

 

(136,116

)

 

 

(173,524

)

 

Deferred costs

 

 

 

(5,453

)

 

 

(4,535

)

 

Hedging activities

 

 

 

-

 

 

 

(22

)

 

Other

 

 

 

(1,083

)

 

 

(1,398

)

 

Total deferred tax liabilities

 

 

 

(158,577

)

 

 

(198,448

)

 

Net deferred tax liabilities

 

 

$

(30,952

)

 

$

(76,309

)

 

 

The tax credit carryforwards can be carried forward indefinitely.

The Company operates in numerous taxing jurisdictions and is subject to regular examinations by various U.S. federal, state and foreign jurisdictions for various tax periods.  Additionally, the Company has retained tax liabilities and the rights to tax refunds in connection with various acquisitions and divestitures of businesses in prior years.  The Company’s income tax positions are based on research and interpretations of income tax laws and rulings in each of the jurisdictions in which the Company does business.  Due to the subjectivity and complexity of the interpretations of the tax laws and rulings in each jurisdiction, the differences and interplay in the tax laws between those jurisdictions as well as the inherent uncertainty in estimating the final resolution of complex tax audit matters, the Company’s estimates of income tax liabilities and assets may differ from actual payments, assessments or refunds.

Management believes that it is more likely than not that the Company will realize the current and long-term deferred tax assets as a result of future taxable income.  Significant factors management considered in determining the probability of the realization of the deferred tax assets include expected future earnings, the Company’s historical operating results and the reversal of deferred tax liabilities.  Accordingly, no valuation allowance has been recorded on the deferred tax assets.

U.S. and various state and foreign income tax returns are open to examination, and presently there are foreign income tax returns under examination.  Such examinations could result in challenges to tax positions taken, and accordingly, the Company may record adjustments to provisions based on the outcomes of such matters.  However, the Company believes that the resolution of these matters, after considering amounts accrued, will not have a material adverse effect on its consolidated financial statements.

The incremental tax benefit received by the Company upon exercise of non-qualified employee stock options was $7.1 million, $3.0 million, and $0.4 million in fiscal years 2014, 2013, and 2012, respectively.


A reconciliation of the U.S. federal statutory income tax rate to the effective income tax rate for each of the fiscal years was as follows:

 

 

2014

 

 

2013

 

 

2012

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

U.S. statutory income tax rate

 

35.0

%

 

 

35.0

%

 

 

35.0

%

 

State income taxes

 

0.5

%

 

 

0.6

%

 

 

0.6

%

 

Foreign taxes

 

-13.4

%

 

 

-11.3

%

 

 

-17.4

%

 

Goodwill impairment

 

0.0

%

 

 

0.6

%

 

 

12.9

%

 

Penalties

 

0.4

%

 

 

1.7

%

 

 

0.0

%

 

Difference in foreign tax rates

 

1.4

%

 

 

-0.7

%

 

 

-1.1

%

 

Domestic manufacturing deduction

 

-1.3

%

 

 

-1.3

%

 

 

-2.1

%

 

Research & development credits

 

-2.5

%

 

 

-3.4

%

 

 

-3.4

%

 

Net change in tax reserves

 

0.1

%

 

 

-2.9

%

 

 

0.5

%

 

Valuation allowance

 

0.0

%

 

 

0.0

%

 

 

-1.0

%

 

Change in foreign tax rates and laws

 

0.0

%

 

 

-1.5

%

 

 

-3.4

%

 

Other, net

 

0.8

%

 

 

-0.4

%

 

 

-1.0

%

 

Effective income tax rate

 

21.0

%

 

 

16.4

%

 

 

19.6

%

 

 

No provision for federal income taxes has been made on accumulated earnings of foreign subsidiaries, since such earnings are considered indefinitely reinvested. The amount of undistributed foreign earnings which are considered to be indefinitely reinvested at October 31, 2014, is approximately $555.4 million.  Furthermore, the Company determined it was not practical to estimate the deferred taxes on these earnings.  The amount of deferred income taxes is not practical to compute due to the complexity of the Company’s international holding company structure, layers of regulatory requirements that have to be evaluated to determine the amount of allowable dividends, numerous potential repatriation scenarios that could be created to facilitate the repatriation of earnings to the U.S., and the complexity of computing foreign tax credits.

A reconciliation of the beginning and ending amount of unrecognized tax benefits is as follows:

 

In Thousands

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Unrecognized tax benefits as of October 25, 2013

 

 

 

$

12,008

 

 

Unrecognized gross benefit change:

 

 

 

 

 

 

 

Gross increase due to prior period adjustments

 

 

 

 

183

 

 

Gross decrease due to prior period adjustments

 

 

 

 

(606

)

 

Gross increase due to current period adjustments

 

 

 

 

868

 

 

Gross decrease due to a lapse with taxing authorities

 

 

 

 

(1,226

)

 

Total change in unrecognized gross benefit

 

 

 

 

(781

)

 

Unrecognized tax benefits as of October 31, 2014

 

 

 

$

11,227

 

 

 

 

 

 

 

 

 

 

 

Unrecognized tax benefits that, if recognized, would impact the effective tax rate

 

 

 

$

10,816

 

 

 

 

 

 

 

 

 

 

 

Statement of operations:

 

 

 

 

 

 

 

Total amount of interest income (expense) included in income tax expense

 

 

 

$

109

 

 

 

 

 

 

 

 

 

 

 

Recognized in the statement of financial position:

 

 

 

 

 

 

 

Total amount of accrued interest included in income taxes payable

 

 

 

$

986

 

 

 

During the next 12 months, it is reasonably possible that approximately $3.3 million of previously unrecognized tax benefits related to operating losses and tax credits could decrease as a result of settlement of examinations and/or the expiration of statutes of limitations.  The Company recognizes interest related to unrecognized tax benefits in income tax expense.


The Company is no longer subject to income tax examinations by tax authorities in its major tax jurisdictions as follows:

 

 

 

Years No Longer

 

Tax Jurisdiction

 

Subject to Audit

 

 

 

 

 

U.S. Federal

 

2008 and prior

 

Canada

 

2006 and prior

 

France

 

2010 and prior

 

United Kingdom

 

2011 and prior