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Income Taxes
6 Months Ended
Apr. 28, 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. Accounting for the remeasurement of deferred tax assets was completed in the fourth quarter of fiscal 2018, and the accounting for the transition tax was 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 $96 million realized by Applied in the first half of fiscal 2019. Proposed regulations are not authoritative and may change in the regulatory review process. This tax benefit may reverse if the regulations are finalized as proposed. An accounting policy choice is allowed to treat GILTI temporary differences in taxable income either 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 second quarter of fiscal 2019 and 2018 were 12.3 percent and 12.8 percent, respectively. The effective tax rate for the second quarter of fiscal 2019 was lower than the same period in the prior fiscal year primarily due to tax expense of $71 million in the second quarter of fiscal 2018 for adjustments to the transition tax and remeasurement of deferred tax assets as a result of the Tax Act. Excluding the tax expense of $71 million, the effective tax rate for the second quarter of fiscal 2019 was higher than the rate in the same period of the prior fiscal year primarily due to changes in the geographical composition of income which includes jurisdictions with differing tax rates.
Applied’s effective tax rates for the first half of fiscal 2019 and 2018 were 12.8 percent and 48.2 percent, respectively. The effective tax rate for the first half of fiscal 2019 was lower than the same period in the prior fiscal year primarily due to tax expense of $1.1 billion in the first half of fiscal 2018 for the transition tax and remeasurement of deferred tax assets as a result of the Tax Act. Excluding the tax expense of $1.1 billion, the effective tax rate for the first half of fiscal 2019 was higher than the rate in the same period of the prior fiscal year primarily due to tax expense of $81 million in the first half of fiscal 2019 related to changes in uncertain tax positions and the excess tax benefit from share-based compensation in the first half of fiscal 2019 being $45 million less than in the same period in the prior fiscal year. The effective tax rate for the first half of fiscal 2019 was also higher due to changes in the geographical composition of income which includes jurisdictions with differing tax rates.