NOTE 10: Income Taxes

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

In Thousands	2016			2015			2014

Current
U.S. Federal	$	14,959		$	11,045		$	27,243
State		(852	)		492			1,732
Foreign		30,314			24,131			28,944
		44,421			35,668			57,919

Deferred
U.S. Federal		(6,703	)		(7,686	)		(1,024	)
State		2,060			(195	)		(10	)
Foreign		(17,243	)		(8,831	)		(13,169	)
		(21,886	)		(16,712	)		(14,203	)
Income tax expense	$	22,535		$	18,956		$	43,716

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

In Thousands	2016		2015		2014

U.S.	$	71,319	$	43,592	$	101,803
Foreign		69,116		72,430		107,495
Earnings from continuing operations before income taxes	$	140,435	$	116,022	$	209,298

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	2016			2015

Reserves and liabilities	$	53,119		$	48,918
Loss carryforwards		51,760			49,667
Tax credit carryforwards		34,836			32,015
Employee benefits		13,853			12,316
Retirement benefits		22,703			17,055
Non-qualified stock options		13,571			11,908
Hedging activities		3,350			6,092
Other		1,003			2,187
Total deferred tax assets		194,195			180,158
Less valuation allowance		(42,976	)		(42,694	)
Total deferred tax assets, net of valuation allowance		151,219			137,464

Depreciation and amortization		(7,456	)		(9,352	)
Intangibles and amortization		(116,620	)		(124,941	)
Deferred costs		(3,907	)		(5,779	)
Other		(1,625	)		(1,180	)
Total deferred tax liabilities		(129,608	)		(141,252	)
Net deferred tax assets (liabilities)	$	21,611		$	(3,788	)

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 other than certain capital and net operating losses. The majority of the losses will expire in fiscal 2020.

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 $0.6 million, $2.0 million, and $7.1 million in fiscal years 2016, 2015, and 2014, 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:

	2016			2015			2014

U.S. statutory income tax rate		35.0	%		35.0	%		35.0	%
Foreign taxes		-9.8	%		-10.7	%		-7.6	%
Difference in foreign tax rates		-4.3	%		-5.2	%		-4.4	%
Research & development credits		-5.0	%		-5.1	%		-2.5	%
Non-deductible under consent agreement		0.0	%		2.2	%		0.4	%
Domestic manufacturing deduction		-1.1	%		-0.7	%		-1.3	%
Net change in tax reserves		-0.6	%		-0.2	%		0.1	%
State income taxes		0.2	%		0.2	%		0.5	%
Other, net		1.6	%		0.8	%		0.7	%
Effective income tax rate		16.0	%		16.3	%		20.9	%

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 September 30, 2016, is approximately $533.5 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 2, 2015	$	10,583
Unrecognized gross benefit change:
Gross decrease due to prior period adjustments		(475	)
Gross increase due to current period adjustments		1,475
Gross decrease due to settlements with taxing authorities		(2,068	)
Gross decrease due to a lapse with taxing authorities		(2,889	)
Total change in unrecognized gross benefit		(3,957	)
Unrecognized tax benefits as of September 30, 2016	$	6,626

Unrecognized tax benefits that, if recognized, would impact the effective tax rate	$	6,626

Statement of operations:
Total amount of interest income (expense) included in income tax expense	$	(308	)

Recognized in the statement of financial position:
Total amount of accrued interest included in income taxes payable	$	583

During the next 12 months, it is reasonably possible that approximately $1.4 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		2012 and prior
Canada		2007 and prior
France		2012 and prior
United Kingdom		2013 and prior