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Income Taxes
9 Months Ended
Jun. 04, 2015
Income Tax Disclosure [Abstract]  
Income Taxes
Income Taxes

Income taxes included $22 million and $93 million for the third quarter and first nine months of 2015, respectively, and $49 million and $177 million for the third quarter and first nine months of 2014, respectively, related to the utilization of deferred tax assets by the MMJ Group. Income taxes for the third quarter of 2015 also included $45 million to write down the value of MMJ's deferred tax assets as a result of changes in Japan tax laws that reduced the corporate tax rate for tax years beginning on or after April 1, 2015 and expanded the taxable base with higher limits on future net operating loss deductions. Remaining taxes for the third quarter and first nine months of 2015 and 2014 primarily reflect taxes on our non-U.S. operations.

We have a full valuation allowance for our net deferred tax asset associated with our U.S. operations.  Management continues to evaluate future projected financial performance to determine whether such performance is sufficient evidence to support a reduction in or reversal of the valuation allowances. The amount of the deferred tax asset considered realizable could be adjusted if significant positive evidence increases. Income taxes on U.S. operations for the third quarter and first nine months of 2015 and 2014 were substantially offset by changes in the valuation allowance.

As of June 4, 2015, we estimate our unrecognized tax benefits may increase for 2015 by approximately $130 million, primarily due to transfer pricing matters, which we would expect to be substantially offset by a change in our valuation allowance. The resolution of tax audits or lapses of statute of limitations could also reduce our unrecognized tax benefits. Although the timing of final resolution is uncertain, the estimated potential reduction in our unrecognized tax benefits in the next 12 months ranges from $0 to $70 million, including interest and penalties.

We operate in a number of locations outside the U.S., including Singapore, where we have tax incentive agreements that are conditional upon meeting certain business operations and employment thresholds. The effect of tax incentive arrangements, which expire in whole or in part at various dates through 2026, reduced our tax provision for the third quarter and first nine months of 2015 by $52 million (benefitting our diluted earnings per share by $0.04) and $289 million ($0.24 per diluted share), respectively. These arrangements reduced our tax provision for the third quarter and first nine months of 2014 by $88 million ($0.07 per diluted share) and $232 million ($0.19 per diluted share), respectively.