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Income Taxes
3 Months Ended
Jan. 31, 2014
Income Tax Disclosure [Abstract]  
Income Taxes
INCOME TAXES
The quarterly provision for income taxes is calculated using an estimated annual effective income tax rate, adjusted for discrete items that occur during the reporting period. The effective tax rates on income before income taxes for the three months ended January 31, 2014 and 2013 were 42.5% and 22.2%, respectively. The year-over-year difference consists primarily of the retroactive reinstatement of the 2012 Work Opportunity Tax Credit (“WOTC”) occurring during our first quarter of fiscal year 2013 and the expiration of the WOTC as of December 31, 2013.
At January 31, 2014, we had unrecognized tax benefits of $87.9 million, $81.2 million of which, if recognized in the future, would impact our effective tax rate. We include interest and penalties related to unrecognized tax benefits in income tax expense. As of January 31, 2014, we had accrued interest and penalties related to uncertain tax positions of $1.6 million, of which $0.3 million was recognized and expensed in the three months ended January 31, 2014.
Our most significant income tax jurisdiction is the United States. The U.S. federal income tax returns for ABM are open for examination for the periods ended October 31, 2010 through October 31, 2013. The federal income tax returns for the Linc entities which are taxable as corporations remain open for examination for the period ended December 31, 2010. The federal income tax returns for Air Serv remain open for examination for the periods ended June 30, 2010 through October 31, 2012. Air Serv is currently being examined by the Internal Revenue Service for its tax year ended June 30, 2011. The federal income tax returns for HHA remain open for examination for the periods ended December 31, 2010 through October 31, 2012. We do business in all 50 states, significantly in California, Texas, and New York, as well as in various foreign jurisdictions. In major state jurisdictions, the tax years 2009–2013 remain open and subject to examination by the appropriate tax authorities. We are currently being examined by the taxing authorities in the states of New York and Texas.