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Income Taxes
3 Months Ended
Jul. 29, 2012
Income Tax Disclosure [Abstract]  
Income Taxes
Income Taxes
The provision for income taxes consists of provisions for federal, state and foreign income taxes. The Company operates in an international environment with almost 70% of its sales outside the U.S. Accordingly, the consolidated income tax rate is a composite rate reflecting the earnings in various locations and the applicable tax rates. In the normal course of business, the Company is subject to examination by taxing authorities throughout the world, including such major jurisdictions as Australia, Canada, Italy, the United Kingdom and the United States. The Company has substantially concluded all national income tax matters for years through Fiscal 2010 for the United Kingdom, through Fiscal 2009 for the U.S., and through Fiscal 2007 for Australia, Canada, and Italy.
During the first quarter of Fiscal 2013, a foreign subsidiary of the Company exercised a tax option under local law to revalue certain of its intangible assets, increasing the local tax basis by $82.1 million. This revaluation resulted in a reduction of tax expense in the first quarter of Fiscal 2013 of $12.9 million, reflecting the deferred tax benefit from the higher tax basis partially offset by the tax liability arising from this revaluation of $13.1 million. As a result of this revaluation and a similar revaluation that occurred during the second quarter of Fiscal 2012, the subsidiary will make tax payments of approximately $18 million during the second quarter of Fiscal 2013, and approximately $16 million and $4 million during Fiscals 2014 and 2015, respectively. The tax benefit from the higher basis amortization of the current period revaluation will result in a reduction in cash taxes over the 20 year tax amortization period totaling $25.8 million partially offset by the $13.1 million tax liability.
The effective tax rate for the three months ended July 29, 2012 was 17.7% compared to 23.3% last year. The decrease in the effective tax rate is primarily the result of the revaluation noted above. Both periods included a benefit related to 200 basis point statutory tax rate reductions in the United Kingdom.
The total amount of gross unrecognized tax benefits for uncertain tax positions, including positions impacting only the timing of tax benefits, was $47.9 million and $52.7 million, on July 29, 2012 and April 29, 2012, respectively. The amount of unrecognized tax benefits that, if recognized, would impact the effective tax rate was $34.4 million and $38.9 million, on July 29, 2012 and April 29, 2012, respectively. It is reasonably possible that the amount of unrecognized tax benefits will decrease by as much as $22.3 million in the next 12 months primarily due to the expiration of statutes of limitations in various foreign jurisdictions along with the progression of federal, state and foreign audits in process.
The Company classifies interest and penalties on tax uncertainties as a component of the provision for income taxes. The total amounts of interest and penalties accrued at July 29, 2012 were $15.9 million and $12.5 million, respectively. The corresponding amounts of accrued interest and penalties at April 29, 2012 were $16.0 million and $13.8 million, respectively.
During August 2012, the Company completed a tax-free reorganization in a foreign jurisdiction which resulted in an increase in the tax basis of both fixed and intangible assets. The increased tax basis is expected to result in a substantial discrete tax benefit for the second quarter and cash flow benefits in future years as a result of the tax deductions of the assets over their amortization periods.