Income Taxes

The provision for income taxes consists of the following:



	Fiscal year ended January 31,
	2016			2015			2014
Federal:
Current	$	(4.7	)	$	(43.8	)	$	29.1
Deferred	220.9			(11.9		)	(41.4		)
State:
Current	0.5			(13.2		)	0.6
Deferred	20.9			9.0			—
Foreign:
Current	68.4			69.5			63.9
Deferred	4.2			(8.4		)	(1.1		)
	$	310.2		$	1.2		$	51.1

Pursuant to accounting standards related to stock-based compensation, the Company has unrecorded excess stock option tax benefits of $233.8 million as of January 31, 2016. These amounts will be credited to additional paid-in-capital when such amounts reduce cash taxes payable. Foreign pretax income was $218.2 million in fiscal 2016, $302.5 million in fiscal 2015, and $380.5 million in fiscal 2014.

The differences between the U.S. statutory rate and the aggregate income tax provision are as follows:



	Fiscal year ended January 31,
	2016			2015			2014
Income tax provision at U.S. Federal statutory rate	$	(7.1	)	$	29.0		$	98.0
State income tax benefit, net of the U.S. Federal benefit	(7.6		)	(4.0		)	(2.9		)
Foreign income taxed at rates different from the U.S. statutory rate	(29.4		)	(40.0		)	(57.1		)
U.S. valuation allowance	345.0			2.9			2.1
Tax effect of non-deductible stock-based compensation	19.3			15.7			10.8
Research and development tax credit benefit	(9.4		)	(7.2		)	(8.8		)
Closure of income tax audits and changes in uncertain tax positions	(4.7		)	(0.7		)	3.6
Tax effect of officer compensation in excess of $1.0 million	1.4			2.4			3.0
Non-deductible expenses	2.6			2.2			2.6
Other	0.1			0.9			(0.2		)
	$	310.2		$	1.2		$	51.1

Autodesk's tax expense was increased by $345.0 million during fiscal 2016 for valuation allowances reducing the Company's U.S. federal and state deferred tax assets to the amount more likely than not to be realized. The effective tax rate impact includes valuation allowances against the deferred tax assets that existed at the beginning of fiscal 2016, and valuation allowances to offset tax attributes generated during fiscal 2016.

The Protecting Americans from Tax Hikes (PATH) Act of 2015 enacted on December 18, 2015 extended and made permanent the federal R&D tax credit. As a result, our income tax provision for Fiscal 2016 includes a tax benefit that reduced our effective annual tax rate. We recorded federal R&D tax benefits of $9.4 million, $7.2 million and $8.8 million during fiscal 2016, 2015, and 2014, respectively. As of January 31, 2016, the deferred tax asset balances for U.S federal and state R&D tax credits were offset by a valuation allowance.

Significant components of Autodesk’s deferred tax assets and liabilities are as follows:



	January 31,
	2016			2015
Stock-based compensation	$	37.5		$	39.9
Research and development tax credit carryforwards	91.3			62.6
Foreign tax credit carryforwards	51.1			—
Accrued compensation and benefits	41.5			43.6
Other accruals not currently deductible for tax	23.6			18.4
Purchased technology and capitalized software	64.3			53.9
Fixed assets	18.6			16.2
Tax loss carryforwards	17.6			16.0
Deferred Revenue	56.7			48.0
Other	13.9			7.4
Total deferred tax assets	416.1			306.0
Less: valuation allowance	(398.0		)	(70.8		)
Net deferred tax assets	18.1			235.2
Indefinite lived intangibles	(54.1		)	(40.7		)
Unremitted earnings of foreign subsidiaries	(22.4		)	(9.4		)
Total deferred tax liabilities	(76.5		)	(50.1		)
Net deferred tax assets	$	(58.4	)	$	185.1

The valuation allowance increased by $327.2 million, $3.6 million, and $15.9 million in fiscal 2016, 2015, and 2014, respectively. The fiscal 2016, 2015, and 2014 changes in valuation allowance were primarily related to U.S. and Canadian deferred taxes. Autodesk recorded a $230.8 million valuation allowance against the Company's U.S. federal and remaining state deferred tax assets recorded in the second quarter of fiscal 2016. Autodesk regularly assesses the need for a valuation allowance against its deferred tax assets. In making that assessment, Autodesk considers both positive and negative evidence, whether it is more likely than not that some or all of the deferred tax assets will not be realized. In evaluating the need for a valuation allowance, Autodesk considered recent cumulative losses in the United States arising from the Company's business model transition as a significant piece of negative evidence and determined that it was not more likely than not that the federal and remaining state deferred tax assets would be realized. As Autodesk continually strives to optimize our overall business model, tax planning strategies may become feasible and prudent allowing us to realize many of the deferred tax assets which are offset by a valuation allowance; therefore, Autodesk will continue to evaluate the realizability of our net deferred tax assets each quarter, both in the US and in foreign jurisdictions, based on all available evidence, both positive and negative.

Autodesk provides U.S. income taxes on the earnings of foreign subsidiaries, except to the extent subsidiaries' earnings are considered permanently reinvested outside the U.S. As of January 31, 2016, the cumulative amount of earnings upon which U.S. income taxes have not been provided was $1,942.2 million. The unrecognized deferred tax liability for these earnings was approximately $544.3 million.

Realization of foreign non-current net deferred tax assets of $9.2 million is dependent upon the company's ability to generate future taxable income in appropriate tax jurisdictions to obtain benefit from the reversal of temporary differences, net operating loss carryforwards and tax credits. The amount of deferred tax assets considered realizable is subject to adjustment in future periods if estimates of future taxable income are reduced and Autodesk then determines that it is not more likely than not to realize such deferred tax assets.

As of January 31, 2016, Autodesk had $222.7 million of cumulative federal tax loss carryforwards and $258.9 million of cumulative state tax loss carryforwards, which may be available to reduce future income tax liabilities in certain jurisdictions. These federal and state tax loss carryforwards will expire beginning fiscal 2019 through fiscal 2037 and fiscal 2019 through fiscal 2037, respectively. Autodesk also had $6.0 million of cumulative UK tax loss carryforwards, which may be available to reduce future income tax liabilities indefinitely. Autodesk had $6.8 million of cumulative federal and state capital loss carryforwards as of January 31, 2016 which are available to offset future capital gains through fiscal 2019.

As of January 31, 2016, Autodesk had $116.2 million of cumulative federal research tax credit carryforwards, $60.9 million of cumulative California state research tax credit carryforwards, and $50.4 million of cumulative Canadian federal tax credit carryforwards, which may be available to reduce future income tax liabilities in the respective jurisdictions. The federal tax credit carryforwards will expire beginning fiscal 2021 through fiscal 2037, the state credit carryforwards may reduce future California income tax liabilities indefinitely, and the Canadian tax credit carryforwards will expire beginning fiscal 2027 through fiscal 2037. Autodesk also has $185.4 million of cumulative foreign tax credit carryforwards, which may be available to reduce future U. S. tax liabilities. The foreign tax credit will expire beginning fiscal 2019 through fiscal 2027.

Utilization of net operating losses and tax credits may be subject to an annual limitation due to ownership change limitations provided in the Internal Revenue Code and similar state provisions. This annual limitation may result in the expiration of net operating losses and credits before utilization.

As a result of certain business and employment actions and capital investments undertaken by Autodesk, income earned in certain Europe and Asia Pacific countries is subject to reduced tax rates through fiscal 2016 and 2020, respectively with extensions available with incremental business and employment actions. We have no net income tax benefits attributable to the tax status of these business arrangements in fiscal 2016, compared to $1.2 million ($0.01 basic net income per share) in fiscal 2015, and $9.7 million ($0.04 basic net income per share) in fiscal 2014. The income tax benefits were offset by accruals of U.S. income taxes on undistributed earnings, among other factors.

As of January 31, 2016, the company had $254.3 million of gross unrecognized tax benefits, of which $236.8 million would impact the effective tax rate, if recognized. However, this rate impact would be offset to the extent that recognition of unrecognized tax benefits currently presented as a reduction of deferred tax assets would increase the valuation allowance.

It is possible that the amount of unrecognized tax benefits will change in the next twelve months; however an estimate of the range of the possible change cannot be made at this time.

A reconciliation of the beginning and ending amount of the gross unrecognized tax benefits is as follows:



	Fiscal Year Ended January 31,
	2016			2015			2014
Gross unrecognized tax benefits at the beginning of the fiscal year	$	245.8		$	222.1		$	212.7
Increases for tax positions of prior years	1.4			3.2			1.8
Decreases for tax positions of prior years	(7.0		)	(2.5		)	(0.3		)
Increases for tax positions related to the current year	15.8			33.2			15.3
Decreases relating to settlements with taxing authorities	(0.5		)	(5.4		)	(4.6		)
Reductions as a result of lapse of the statute of limitations	(1.2		)	(4.8		)	(2.8		)
Gross unrecognized tax benefits at the end of the fiscal year	$	254.3		$	245.8		$	222.1

It is the company's continuing practice to recognize interest and/or penalties related to income tax matters in income tax expense. Autodesk had $3.3 million, $2.0 million, and $2.8 million, net of tax benefit, accrued for interest and penalties related to unrecognized tax benefits as of January 31, 2016, 2015, and 2014, respectively.

Autodesk and its subsidiaries are subject to income tax in the United States as well as numerous state and foreign jurisdictions. Autodesk's U.S. and state income tax returns for fiscal year 2003 through fiscal year 2016 remain open to examination. In addition, Autodesk files tax returns in multiple foreign taxing jurisdictions with open tax years ranging from fiscal year 2004 to 2016.