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Income Taxes
9 Months Ended
Jul. 26, 2020
Income Tax Disclosure [Abstract]  
Income Taxes Income Taxes
Applied’s provision for income taxes and effective tax rate are affected by the geographical composition of pre-tax income which includes jurisdictions with differing tax rates, conditional reduced tax rates and other income tax incentives. It is also affected by events that are not consistent from period to period, such as changes in income tax laws and the resolution of prior years’ income tax filings.
On June 14, 2019, the U.S. government released regulations that significantly affect how the global intangible low-taxed income (GILTI) provision of the Tax Act is interpreted. As a result, Applied reversed a tax benefit of $96 million in the third quarter of fiscal 2019 that had been realized in the first half of fiscal 2019.
On March 27, 2020, the U.S. government enacted the Coronavirus Aid, Relief, and Economic Security Act (CARES Act). The enactment of the CARES Act does not result in any material adjustments to Applied’s provision for income taxes.
Applied’s effective tax rates for the third quarter of fiscal 2020 and 2019 were 19.1 percent and 27.0 percent, respectively. The effective tax rate for the third quarter of fiscal 2020 was lower than the same period in the prior fiscal year primarily due to a tax expense taken in the third quarter of fiscal 2019 for regulations issued that significantly affected how the GILTI provisions of the Tax Act were interpreted. This was partially offset by the settlement of certain unrecognized tax benefits that resulted in an additional income tax expense of $44 million in the third quarter of fiscal 2020.
Applied’s effective tax rates for the first nine months of fiscal 2020 and 2019 were 14.9 percent and 17.3 percent, respectively. The effective tax rate for the first nine months of fiscal 2020 was lower than the same period in the prior fiscal year primarily due to higher excess tax benefits from share-based compensation. This was partially offset by the settlement of certain unrecognized tax benefits that resulted in an additional income tax expense of $44 million during the first nine months of fiscal 2020.
During the next twelve months, it is reasonably possible that unrecognized tax benefits related to certain tax positions taken on previously filed tax returns could be recognized in the amount of approximately $139 million as a result of negotiations with tax authorities and lapses of statutes of limitation.