XML 31 R19.htm IDEA: XBRL DOCUMENT v3.10.0.1
Income Taxes
9 Months Ended
Jul. 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 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 third quarter of fiscal 2018 and 2017 were 5.3 percent and 5.4 percent, respectively. The third quarter of fiscal 2018 included tax benefits from the resolution of tax liabilities for uncertain tax positions, the lower U.S. federal corporate tax rate, and changes in the geographical composition of income. The third quarter of the prior fiscal year included tax benefits from the recognition of previously unrecognized foreign tax credits.
Applied’s effective tax rates for the first nine months fiscal 2018 and 2017 were 34.1 percent and 7.7 percent, respectively. The first nine months of fiscal 2018 included tax expense of $1.1 billion for the transition tax and remeasurement of deferred tax assets partially offset by tax benefits from the lower U.S. federal corporate tax rate, changes in the geographical composition of income, adoption of authoritative guidance for share-based compensation, and the resolution of tax liabilities for uncertain tax positions. The first nine months of the prior fiscal year included tax benefits from the recognition of previously unrecognized foreign tax credits.