Income Taxes (Tables)

12 Months Ended

Aug. 28, 2014



For the year ended	2014			2013			2012
Income (loss) before income taxes, net income attributable to noncontrolling interests and equity in net income (loss) of equity method investees:
Foreign	$	2,619		$	839		$	274
U.S.	114			446			(1,028		)
	$	2,733		$	1,285		$	(754	)

Income tax (provision) benefit:
Current:
Foreign	$	(46	)	$	(17	)	$	(22	)
U.S. federal	(3		)	—			14
State	(2		)	—			—
	(51		)	(17		)	(8		)
Deferred:
Foreign	(81		)	9			25
U.S. federal	4			—			—
	(77		)	9			25
Income tax (provision) benefit	$	(128	)	$	(8	)	$	17

Income tax (provision) benefit computed using the U.S. federal statutory rate reconciled to income tax (provision) benefit

Income tax (provision) benefit computed using the U.S. federal statutory rate reconciled to income tax (provision) benefit was as follows:



For the year ended	2014			2013			2012
U.S. federal income tax (provision) benefit at statutory rate	$	(956	)	$	(450	)	$	264
Change in unrecognized tax benefits	(152		)	2			52
State taxes, net of federal benefit	(39		)	6			9
Gain on MMJ Acquisition	(11		)	520			—
Change in valuation allowance	544			(418		)	(368		)
Foreign tax rate differential	474			339			77
Tax credits	11			36			2
Transaction costs related to the MMJ Acquisition	—			(38		)	—
Other	1			(5		)	(19		)
Income tax (provision) benefit	$	(128	)	$	(8	)	$	17

Deferred tax assets and liabilities

Deferred tax assets and liabilities consist of the following:



As of	2014			2013
Deferred tax assets:
Net operating loss and tax credit carryforwards	$	3,162		$	4,048
Property, plant and equipment	284			313
Accrued salaries, wages and benefits	152			107
Other accrued liabilities	113			8
Other	104			169
Gross deferred tax assets	3,815			4,645
Less valuation allowance	(2,443		)	(3,155		)
Deferred tax assets, net of valuation allowance	1,372			1,490

Deferred tax liabilities:
Debt discount	(291		)	(294		)
Unremitted earnings on certain subsidiaries	(115		)	(126		)
Product and process technology	(29		)	(74		)
Other	(67		)	(14		)
Deferred tax liabilities	(502		)	(508		)

Net deferred tax assets	$	870		$	982

Reported as:
Current deferred tax assets (included in other current assets)	$	228		$	123
Noncurrent deferred tax assets	816			861
Current deferred tax liabilities (included in accounts payable and accrued expenses)	(4		)	(2		)
Noncurrent deferred tax liabilities (included in other noncurrent liabilities)	(170		)	—
Net deferred tax assets	$	870		$	982

Net operating loss carryforwards

As of August 28, 2014, our federal, state and foreign net operating loss carryforward amounts and expiration periods as reported to tax authorities, were as follows:



Year of Expiration	U.S. Federal		State		Japan		Other Foreign		Total
2015 - 2019	$	—	$	102	$	83	$	513	$	698
2020 - 2024	—		179		3,862		872		4,913
2025 - 2029	2,081		934		—		—		3,015
2030 - 2033	1,812		493		—		—		2,305
Indefinite	—		—		—		39		39
	$	3,893	$	1,708	$	3,945	$	1,424	$	10,970

Federal and state tax credit carryforwards

As of August 28, 2014, our federal and state tax credit carryforward amounts and expiration periods were as follows:



Year of Tax Credit Expiration	Federal		State		Total
2015 - 2019	$	9	$	69	$	78
2020 - 2024	91		55		146
2025 - 2029	78		38		116
2030 - 2034	72		—		72
Indefinite	—		31		31
	$	250	$	193	$	443

Reconciliation of beginning and ending amount of unrecognized tax benefits

Below is a reconciliation of the beginning and ending amount of unrecognized tax benefits:



For the year ended	2014			2013			2012
Beginning unrecognized tax benefits	$	78		$	77		$	121
Increases related to tax positions taken during current year	152			4			6
Foreign currency translation increases (decreases) to tax positions	1			4			(9		)
Settlements with tax authorities	(1		)	(8		)	(29		)
Decreases related to tax positions from prior years	(1		)	—			(14		)
Lapse of statute of limitations	(1		)	—			—
Increases related to tax positions from prior years	—			—			2
Unrecognized tax benefits acquired in current year	—			1			—
Ending unrecognized tax benefits	$	228		$	78		$	77

- Definition

Tabular disclosure of tax positions taken in the tax returns filed or to be filed for which it is more likely than not that the tax position will not be sustained upon examination by taxing authorities (i.e., uncertain tax positions) and other types of income tax contingencies, including: (1) the policy on classification of interest and penalties; (2) a tabular reconciliation of the total amounts of unrecognized tax benefits at the beginning and end of the period; the total amount(s) of: (3) unrecognized tax benefits that, if recognized, would affect the effective tax rate, and (4) interest and penalties recognized in each of the income statement and balance sheet; (5) for positions for which it is reasonably possible that the total amounts unrecognized will significantly change within 12 months of the reporting date the: (i) nature of the uncertainty, (ii) nature of the event that could occur that would cause the change, and (iii) an estimate of the range of the reasonably possible change or a statement that an estimate of the range cannot be made; and (6) a description of tax years that remain subject to examination by major tax jurisdictions.

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