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Income Taxes
12 Months Ended
Apr. 30, 2021
Income Tax Disclosure [Abstract]  
Income Taxes

9. Income Taxes

 

Income from continuing operations before provision for income taxes was as follows:

 

 

Year Ended April 30,

 

 

 

2021

 

 

2020

 

 

2019

 

 

 

(in thousands)

 

Domestic

 

$

34,661

 

 

$

40,736

 

 

$

(22,039

)

Foreign

 

 

129,039

 

 

 

110,226

 

 

 

156,379

 

Income before provision for income taxes

 

$

163,700

 

 

$

150,962

 

 

$

134,340

 

The provision for domestic and foreign income taxes was as follows:

 

 

Year Ended April 30,

 

 

 

2021

 

 

2020

 

 

2019

 

 

 

(in thousands)

 

Current income taxes:

 

 

 

 

 

 

 

 

 

 

 

 

Federal

 

$

16,913

 

 

$

14,336

 

 

$

6,152

 

State

 

 

4,719

 

 

 

4,974

 

 

 

9,097

 

Foreign

 

 

40,646

 

 

 

33,965

 

 

 

42,091

 

Current provision for income taxes

 

 

62,278

 

 

 

53,275

 

 

 

57,340

 

Deferred income taxes:

 

 

 

 

 

 

 

 

 

 

 

 

Federal

 

 

(5,809

)

 

 

(6,862

)

 

 

(16,211

)

State

 

 

(5,025

)

 

 

(784

)

 

 

(7,682

)

Foreign

 

 

(3,306

)

 

 

(1,684

)

 

 

(3,903

)

Deferred benefit for income taxes

 

 

(14,140

)

 

 

(9,330

)

 

 

(27,796

)

Total provision for income taxes

 

$

48,138

 

 

$

43,945

 

 

$

29,544

 

 

The reconciliation of the statutory federal income tax rate to the effective consolidated tax rate is as follows:

 

 

 

Year Ended April 30,

 

 

 

2021

 

 

2020

 

 

2019

 

U.S. federal statutory income tax rate

 

 

21.0

%

 

 

21.0

%

 

 

21.0

%

State tax, net of federal effect

 

 

1.0

 

 

 

2.2

 

 

 

1.1

 

Foreign tax rates differential

 

 

4.5

 

 

 

4.5

 

 

 

5.0

 

Non-deductible officers compensation

 

 

2.3

 

 

 

0.5

 

 

 

1.1

 

Excess tax expense (benefit) on stock-based compensation

 

 

0.8

 

 

 

(1.0

)

 

 

(3.1

)

Change in valuation allowance

 

 

0.3

 

 

 

 

 

 

(2.0

)

COLI increase, net

 

 

(1.7

)

 

 

(0.9

)

 

 

(1.0

)

Change in uncertain tax positions

 

 

1.1

 

 

 

0.2

 

 

 

0.1

 

Other

 

 

0.1

 

 

 

2.6

 

 

 

(0.2

)

Effective income tax rate

 

 

29.4

%

 

 

29.1

%

 

 

22.0

%

Components of deferred tax assets and liabilities were as follows:

 

 

 

April 30,

 

 

 

2021

 

 

2020

 

 

 

(in thousands)

 

Deferred tax assets:

 

 

 

 

 

 

 

 

Deferred compensation

 

$

107,834

 

 

$

86,479

 

Operating lease liability

 

 

34,183

 

 

 

37,934

 

Loss carryforwards

 

 

39,704

 

 

 

27,845

 

Reserves and accruals

 

 

16,393

 

 

 

14,211

 

Allowance for doubtful accounts

 

 

4,885

 

 

 

4,029

 

Other

 

 

 

 

 

2,703

 

Gross deferred tax assets

 

 

202,999

 

 

 

173,201

 

Deferred tax liabilities:

 

 

 

 

 

 

 

 

Operating lease, right-of-use, assets

 

 

(27,777

)

 

 

(29,998

)

Intangibles and Goodwill

 

 

(26,570

)

 

 

(29,006

)

Property and equipment

 

 

(20,590

)

 

 

(22,332

)

Prepaid expenses

 

 

(23,928

)

 

 

(19,567

)

Marketable Securities

 

 

(7,003

)

 

 

 

Other

 

 

(2,684

)

 

 

 

Gross deferred tax liabilities

 

 

(108,552

)

 

 

(100,903

)

Valuation allowances

 

 

(25,173

)

 

 

(17,875

)

Net deferred tax asset

 

$

69,274

 

 

$

54,423

 

 

Deferred tax assets are reduced by a valuation allowance if it is more-likely-than-not that some portion or all of the deferred tax assets will not be realized. Management believes uncertainty exists regarding the realizability of certain deferred tax assets and has, therefore, established a valuation allowance for deferred tax assets that are not more-likely-than-not to be realized. Realization of the deferred tax asset is dependent on the Company generating enough taxable income of the appropriate nature in future years. Although realization is not assured, management believes that it is more likely than-not that the net deferred tax assets will be realized. Deferred tax assets and deferred tax liabilities are presented net on the consolidated balance sheets by tax jurisdiction.

As of April 30, 2021, the Company had U.S. federal net operating loss carryforwards of $2.2 million, which the Company anticipates will be fully utilized by fiscal 2028. The Company has state net operating loss carryforwards of $40.3 million, which, if unutilized, will begin to expire in fiscal 2022. The Company also has foreign net operating loss carryforwards of $159.3 million, which, if unutilized, will begin to expire in fiscal 2022.

We continue to consider approximately $571.3 million of undistributed earnings of our foreign subsidiaries to be indefinitely reinvested, and, accordingly, have provided no taxes on such earnings other than the Transition Tax. While we do not anticipate a need to repatriate funds to the U.S. to satisfy domestic liquidity needs, we review our cash positions regularly and, to the extent we determine that all or a portion of our foreign earnings are not indefinitely reinvested, we provide additional taxes, if applicable, including foreign withholding taxes and U.S. state income taxes.

The Company elected to treat taxes due on future U.S. inclusions in taxable income related to Global Intangible Low-Taxed Income as an expense when incurred (the “period cost method”) as opposed to factoring such amounts in the Company’s measurement of its deferred taxes (the “deferred method”).

The Company and its subsidiaries file federal and state income tax returns in the U.S. as well as in foreign jurisdictions. These income tax returns are subject to audit by the Internal Revenue Service (the “IRS”) and various state and foreign tax authorities. Currently, income tax returns of the Company’s subsidiaries are under audit in Brazil, Germany, Switzerland, Japan and India. The Company’s income tax returns are not otherwise under examination in any material jurisdictions. The statute of limitations varies by jurisdiction in which the Company operates. With few exceptions, however, the Company’s tax returns for years prior to fiscal 2015 are no longer open to examination by tax authorities (including U.S. federal, state and foreign).

Unrecognized tax benefits are the differences between the amount of benefits of tax positions taken, or expected to be taken, on a tax return and the amount of benefits recognized for financial reporting purposes. As of April 30, 2021, the Company had a liability of $10.0 million for unrecognized tax benefits. A reconciliation of the beginning and ending balances of the unrecognized tax benefits is as follows:

 

 

 

Year Ended April 30,

 

 

 

2021

 

 

2020

 

 

2019

 

 

 

(in thousands)

 

Unrecognized tax benefits, beginning of year

 

$

6,037

 

 

$

7,794

 

 

$

3,674

 

Settlement with tax authority

 

 

 

 

 

(1,767

)

 

 

(1,771

)

Additions based on tax positions related to the current year

 

 

1,716

 

 

 

10

 

 

 

1,775

 

Additions based on tax positions related to prior years

 

 

2,201

 

 

 

 

 

 

4,116

 

Unrecognized tax benefits, end of year

 

$

9,954

 

 

$

6,037

 

 

$

7,794

 

 

The full amount of unrecognized tax benefits would impact the effective tax rate if recognized. In the next 12 months, it is reasonably possible that the Company’s unrecognized tax benefits could change due to the resolution of certain tax matters either because the tax positions are sustained on audit or the Company agrees to their disallowance. These resolutions could reduce the Company’s liability for unrecognized tax benefits by approximately $1.3 million. The Company does not expect a change in the amount of unrecognized tax benefits to have a material financial statement impact.

The Company classifies interest and penalties related to unrecognized tax benefits as a component of the provision for income taxes. The Company had accruals of $0.9 million, $0.6 million, and $0.4 million for interest related to unrecognized tax benefits as of April 30, 2021, 2020, and 2019 respectively. The Company had an accrual of $0.5 million as of April 30, 2021, for penalties related to unrecognized tax benefits and no accrual for penalties related to unrecognized tax benefits in fiscal 2020 and 2019. The Company recognized tax expense of $0.8 million, $0.2 million, and $0.1 million for interest and penalties related to unrecognized tax benefits during fiscal 2021, 2020, and 2019, respectively.