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Income Taxes
6 Months Ended
Apr. 29, 2018
Income Tax Disclosure [Abstract]  
Income Taxes
Income Taxes
On December 22, 2017, the U.S. government enacted the Tax Cuts and Jobs Act. The Tax Act includes 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 were subject to remeasurement due to the reduction of the U.S. federal corporate tax rate. Applied has a blended U.S. federal corporate tax rate of 23.4 percent for fiscal year 2018 based on the number of days before and after the effective date of the Tax Act.
The U.S. Securities and Exchange Commission issued Staff Accounting Bulletin No. 118 (SAB 118), which provides guidance on accounting for the income tax effects of the Tax Act. SAB 118 provides a measurement period for companies to complete this accounting. 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 income tax effects of the Tax Act will be completed during the measurement period, which will not extend beyond one year from the Tax Act enactment date.
The transition tax is a tax on previously untaxed accumulated earnings and profits (“E&P”) of foreign subsidiaries. To determine the amount of the transition tax, the amount of post-1986 E&P of foreign subsidiaries, as well as the amount of foreign income taxes paid on such earnings, must be calculated. Additional information is being gathered to more precisely compute the transition tax.
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. An accounting policy choice has not yet been made.
Applied’s effective tax rates for the second quarter of fiscal 2018 and 2017 were 12.8 percent and 9.3 percent, respectively. The effective tax rate for the second quarter of fiscal 2018 was higher than in the same period in the prior year primarily due to $71 million of income tax expense in the second quarter of fiscal 2018 related to adjustments in the transition tax and the remeasurement of U.S. deferred tax assets under the Tax Act. Applied’s effective tax rates for the first half of fiscal 2018 and 2017 were 48.6 percent and 9.1 percent, respectively. The effective tax rate for the first half of fiscal 2018 was higher than in the same period in the prior year primarily due to $1.1 billion of income tax expense for the transition tax and the decrease in U.S. deferred tax assets under the Tax Act. This was partially offset by the recognition of a tax benefit of $53 million related to the adoption of authoritative guidance for share-based compensation, 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 $44 million as a result of negotiations with taxing authorities and the expiration of statutes of limitation.