INCOME TAXES

12 Months Ended

Jul. 31, 2023

Income Tax Disclosure [Abstract]

INCOME TAXES

INCOME TAXES

The sources of income before income taxes are as follows:

	For the Fiscal Year Ended July 31,
	2023		2022		2021
United States	$	315,939	$	1,359,841	$	725,262
Foreign	183,414		100,023		119,319
Total	$	499,353	$	1,459,864	$	844,581

The components of the provision for income taxes are as follows:

	For the Fiscal Year Ended July 31,
Income Taxes:	2023		2022		2021
U.S. Federal	$	102,919	$	296,716	$	148,706
U.S. state and local	14,803		55,159		26,344
Foreign	45,174		17,848		17,571
Total current expense	162,896		369,723		192,621
U.S. Federal	(28,819)		(21,317)		162
U.S. state and local	(3,447)		(2,089)		(365)
Foreign	(5,517)		(24,696)		(8,707)
Total deferred expense (benefit)	(37,783)		(48,102)		(8,910)
Total income tax expense	$	125,113	$	321,621	$	183,711

On March 11, 2021, the American Rescue Plan Act (the “Act”) was signed into law. The Act includes several changes impacting business, including but not limited to insurance premium subsidies, extension of employee retention tax credits and amendments to deductible compensation. The Company determined that the impacts of the Act are not material to the Consolidated Financial Statements.

On August 16, 2022, the Inflation Reduction Act was signed into law. Among other provisions, the law provides for a 1% tax imposed on the fair market value of shares repurchased by issuers whose shares are traded on an established securities market, subject to certain exceptions. The tax applies to repurchases made after December 31, 2022 and the Company has determined that the excise tax will not have a material impact to the Consolidated Financial Statements.

The differences between income tax expense at the federal statutory rate and the actual income tax expense are as follows:

	For the Fiscal Year Ended July 31,
	2023		2022		2021
Provision at federal statutory rate	$	104,864	$	306,571	$	177,362
Differences between U.S. Federal statutory and foreign tax rates	(41,300)		58,573		(16,857)
Foreign currency remeasurement (gains) losses	33,737		(73,914)		1,595
U.S. state and local income taxes, net of federal benefit	9,524		38,919		20,407
Global Intangible Low-Taxed Income	10,936		2,000		—
Other	7,352		(10,528)		1,204
Total income tax expense	$	125,113	$	321,621	$	183,711

A summary of the deferred income tax balances is as follows:

	July 31,
	2023		2022
Deferred income tax asset (liability):
Inventory basis	$	10,226	$	6,596
Employee benefits	10,306		10,171
Self-insurance reserves	4,968		6,792
Accrued product warranties	71,800		68,083
Accrued incentives	9,110		7,064
Sales returns and allowances	2,282		2,447
Accrued expenses	5,641		4,866
Property, plant and equipment	(49,036)		(44,508)
Operating leases	13,086		11,193
Deferred compensation	29,667		26,924
Intangibles	(212,478)		(219,726)
Net operating loss and other carryforwards	38,064		40,814
Unrealized loss	(8,843)		(17,925)
Unrecognized tax benefits	2,965		4,013
Research and development	10,816		—
Other	2,395		(6,155)
Valuation allowance	(10,867)		(8,630)
Deferred income tax (liability), net	$	(69,898)	$	(107,981)

Deferred tax assets are reduced by a valuation allowance if, based upon available evidence, it is more likely than not that some, or all, of the deferred tax assets will not be realized. The valuation allowances recorded at July 31, 2023 and July 31, 2022 relate to certain foreign net operating loss carry forwards and other assets in foreign jurisdictions.

With the exception of foreign subsidiary investment basis differences not attributable to un-repatriated foreign earnings, we consider all of our undistributed earnings of our foreign subsidiaries, as of July 31, 2023, to not be indefinitely reinvested outside of the United States. As of July 31, 2023, the related income tax cost of the repatriation of foreign earnings is not material.

As of July 31, 2023, the Company has $414 of U.S. state tax credit carry forwards that expire in fiscal 2033, which the Company expects to realize prior to expiration. At July 31, 2023, the Company had $90,284 of gross NOL carry forwards in certain foreign jurisdictions that will expire from fiscal 2024 to indefinite carryforward, of which $60,905 has been fully reserved with a valuation allowance and the remaining amount the Company expects to realize. In addition, the Company has $5,100 of gross U.S. state tax NOL carryforwards that expire from fiscal 2024 to 2043 that the Company does not expect to realize and therefore has been fully reserved with a valuation allowance.

The benefits of tax positions reflected on income tax returns but whose outcome remains uncertain are only recognized for financial accounting purposes if they meet minimum recognition thresholds. The total amount of unrecognized tax benefits that, if recognized, would have impacted the Company’s effective tax rate were $11,106 for fiscal 2023, $14,461 for fiscal 2022 and $13,631 for fiscal 2021.

Changes in the unrecognized tax benefit during fiscal years 2023, 2022 and 2021 were as follows:

 

	2023		2022		2021
Beginning balance	$	17,998	$	17,025	$	14,238
Tax positions related to prior years:
Additions	649		705		72
Reductions	(1,588)		(1,280)		(277)
Tax positions related to current year:
Additions	974		4,660		4,346
Settlements	(2,531)		(2,453)		(3,363)
Lapses in statute of limitations	(1,790)		(3,010)		(2,701)
Tax positions acquired	—		2,351		4,710
Ending balance	$	13,712	$	17,998	$	17,025

It is the Company’s policy to recognize interest and penalties accrued relative to unrecognized tax benefits in income tax expense. The total amount of liabilities accrued for interest and penalties related to unrecognized tax benefits as of July 31, 2023 and July 31, 2022 were $2,694 and $2,867, respectively. The total amount of interest and penalties expense recognized in the Consolidated Statements of Income and Comprehensive Income for the fiscal years ended July 31, 2023, July 31, 2022 and July 31, 2021 were $523, $134 and $238, respectively.

The total unrecognized tax benefits above, along with the related accrued interest and penalties, are reported within the liability section of the Consolidated Balance Sheets. A portion of the unrecognized tax benefits is classified as short-term and is included in the “Income and other taxes” line of the Consolidated Balance Sheets, while the remainder is classified as a long-term liability.

The components of total unrecognized tax benefits are summarized as follows:

	July 31,
	2023		2022
Unrecognized tax benefits	$	13,712	$	17,998
Reduction to unrecognized tax benefits which offset tax credit and loss carryforwards	(414)		(668)
Accrued interest and penalties	2,694		2,867
Total unrecognized tax benefits	$	15,992	$	20,197
Short-term, included in “Income and other taxes”	$	1,157	$	2,954
Long-term	14,835		17,243
Total unrecognized tax benefits	$	15,992	$	20,197

Within the next 12 months, the Company does not anticipate any material changes in its unrecognized tax benefits as of July 31, 2023.

The Company files income tax returns in the U.S. federal jurisdiction and in many U.S. state and foreign jurisdictions. The Company is currently under exam by certain foreign jurisdictions for fiscal years ended 2016 through 2021. The Company believes it has adequately reserved for its exposure to additional payments for uncertain tax positions in its liability for unrecognized tax benefits.

The major tax jurisdictions we file in, with the years still subject to income tax examinations, are listed below:

 

Major Tax Jurisdiction	Tax Years Subject to Exam
United States – Federal	Fiscal 2020 – Fiscal 2022
United States – State	Fiscal 2020 – Fiscal 2022
Germany	Fiscal 2016 – Fiscal 2021
France	Fiscal 2020 – Fiscal 2022
Italy	Fiscal 2016– Fiscal 2021
United Kingdom	Fiscal 2022