XML 29 R18.htm IDEA: XBRL DOCUMENT v3.8.0.1
Income Taxes
3 Months Ended
Jan. 28, 2018
Income Tax Disclosure [Abstract]  
Income Taxes
Income Taxes
On December 22, 2017, the U.S. government enacted tax legislation referred to as the Tax Cuts and Jobs Act (the “Tax Act”). The Tax Act included a reduction to the U.S. federal corporate tax rate from 35.0 percent to 21.0 percent and requires a one-time transition tax on certain unrepatriated earnings of foreign subsidiaries payable over eight years. U.S. deferred tax assets and liabilities will be subject to remeasurement due to the reduction of the U.S. federal corporate tax rate. Applied’s fiscal year 2018 will have a blended U.S. federal corporate tax rate of 23.4 percent based on the number of days before and after the effective date of the Tax Act.
The U.S. Securities and Exchange Commission (the “SEC”) staff issued Staff Accounting Bulletin (“SAB”) No. 118, which provides guidance on accounting for the tax effects of the Tax Act. SAB 118 provides a measurement period that will not extend beyond one year from the Tax Act enactment date for companies to complete the accounting under Accounting Standards Codification (“ASC”) 740. Pursuant to this guidance, provisional adjustments were recorded when reasonable estimates could be determined. No adjustments were recorded when reasonable estimates could not be determined. These provisional estimates will be revised as information becomes available and as guidance is issued by the Internal Revenue Service. The accounting for the tax effects of the Tax Act will be completed during the measurement period.
The transition tax is a tax on previously untaxed accumulated and current earnings and profits (“E&P”) of certain foreign subsidiaries. To determine the amount of the transition tax, the amount of post-1986 E&P of relevant subsidiaries, as well as the amount of foreign income taxes paid on such earnings, must be calculated. A transition tax expense was recorded in the first fiscal quarter 2018 based on reasonable estimates of foreign subsidiaries E&P. Additional information is being gathered to more precisely compute the transition tax which will be completed during the measurement period.
Tax expense was also recorded based on the decrease in U.S. deferred tax assets due to the reduction of the U.S. federal corporate tax rate from 35.0 percent to 21.0 percent. Tax expense from the decrease in net U.S. deferred tax assets may be affected by other analyses related to the Tax Act, including the calculation of deemed repatriation of deferred foreign income and the state tax effect of adjustments made to federal temporary differences. Valuation allowance analyses are affected by various provisions of the Tax Act (e.g., deemed repatriation of deferred foreign income, global intangible low taxed income inclusions and new categories of foreign tax credits). Since Applied has recorded provisional estimates related to certain portions of the Tax Act, any corresponding determination of the need for or change in a valuation allowance is also provisional.
The Tax Act also includes provisions that do not affect Applied in fiscal 2018, including a provision designed to tax global intangible low-taxed income (“GILTI”). Due to the complexity of the GILTI tax rules, this provision and related tax accounting will continue to be evaluated. An accounting policy choice is allowed to either treat taxes due on future U.S. inclusions in taxable income related to GILTI as a current-period expense when incurred (the “period cost method”) or factor such amounts into the measurement of deferred taxes (the “deferred method”). The calculation of the deferred balance with respect to the new GILTI tax provisions will depend, in part, on analyzing global income to determine whether future U.S. inclusions in taxable income are expected related to GILTI and, if so, what the impact is expected to be, and an accounting policy choice has not yet been made.
Applied’s effective tax rates for the first quarters of fiscal 2018 and 2017 were 88.4 percent and 8.8 percent, respectively. The effective tax rate for the first quarter of fiscal 2018 was higher compared to the same quarter in the prior year primarily due to $1.0 billion of income tax expense related to the Tax Act for the transition tax and the decrease in U.S. deferred tax assets. Tax expense in the first quarter of fiscal 2018 was partially offset by adoption of authoritative guidance for share-based compensation that resulted in the recognition of excess tax benefits of $51 million in provision for income taxes rather than paid-in capital, and by the effect of the lower U.S. federal corporate tax rate and changes in the geographical composition of income.
During the next twelve months, it is reasonably possible that existing liabilities for unrecognized tax benefits could be reduced by approximately $13 million as a result of negotiations with taxing authorities and the expiration of statutes of limitation.