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Income Taxes
3 Months Ended
Jan. 27, 2019
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”). The Tax Act 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. The U.S. Securities and Exchange Commission issued Staff Accounting Bulletin No. 118, which provided guidance on accounting for the income tax effects of the Tax Act and a measurement period for companies to complete this accounting. Applied completed the accounting for the Tax Act during the measurement period, which ended one year after the enactment date of the Tax Act, including the accounting for the remeasurement of deferred tax assets completed in the fourth quarter of fiscal 2018 and the accounting for the transition tax completed in the first quarter of fiscal 2019.
The Tax Act also includes provisions that impact Applied starting in fiscal 2019, including a provision designed to tax global intangible low-taxed income (“GILTI”). On September 13, 2018, the U.S. government issued proposed regulations that, if finalized, would significantly affect how the Tax Act is interpreted related to a tax benefit of $46 million realized by Applied in the first quarter of fiscal 2019. Proposed regulations are not authoritative and may change in the regulatory review process. Pursuant to our accounting policies for uncertain tax positions, the tax benefit might reverse if the regulations are finalized as proposed. An accounting policy choice is allowed to either treat taxes due on future U.S. inclusions related to GILTI in taxable income as a current-period expense when incurred (the “period cost method”) or factor such amounts into the measurement of deferred taxes (the “deferred method”). Applied has chosen the period cost method.
Applied’s effective tax rates for the first quarter of fiscal 2019 and 2018 were 13.2 percent and 86.1 percent, respectively. The effective tax rate for the first quarter of fiscal 2019 was lower than the same period in the prior fiscal year primarily due to tax expense of $1.0 billion in the first quarter of fiscal 2018 for the transition tax and remeasurement of deferred tax assets as a result of the Tax Act. This decrease was partially offset by tax expense in the first quarter of fiscal 2019 related to the resolution of tax liabilities for uncertain tax positions and by the excess tax benefit from share-based compensation being lower in the first quarter of fiscal 2019 than in the same period in the prior fiscal year. The first quarter of fiscal 2019 also included tax expense related to GILTI and changes in the geographical composition of income which includes jurisdictions with differing tax rates.