INCOME TAXES

On December 22, 2017, the Tax Act was enacted into law, which, among other provisions, reduced the federal corporate income tax rate from 35% to 21% and required companies to pay a one-time transition tax on the deemed repatriation of indefinitely reinvested earnings of international subsidiaries. Since we have an October 31 fiscal year-end, the lower corporate income tax rate was phased in, resulting in a U.S. statutory federal rate of 23.3% for fiscal 2018 and 21% for subsequent fiscal years. Other provisions under the Tax Act became effective for us in fiscal 2019, including limitations on deductibility of interest and executive compensation as well as a new minimum tax on Global Intangible Low-Taxed Income (“GILTI”), which we have elected to account for as a period cost.

Due to the complexities of implementing the provisions of the Tax Act, the staff of the SEC issued Staff Accounting Bulletin 118 to provide guidance on accounting for the tax effects of the Tax Act and permitted companies to record provisional amounts during a measurement period not to exceed one year from the enactment date. During the first quarter of 2018, we remeasured certain deferred tax assets and liabilities based on the new tax rates at which they were expected to reverse in the future and recorded a provisional one-time tax benefit of $28.7 million related to this remeasurement. In addition, we recorded a provisional expense of $7.0 million for the one-time transition tax on the deemed repatriation of indefinitely reinvested earnings of our international subsidiaries. We completed our analysis of the impacts of these provisions under the Tax Act as of October 31, 2018, and recorded adjustments during the fourth quarter of 2018 that (i) increased the benefit to $29.6 million for the remeasurement of certain deferred tax assets and liabilities and (ii) decreased the expense to $4.5 million for the one-time transition tax on the deemed repatriation of indefinitely reinvested earnings of our international subsidiaries. We plan to reinvest our foreign earnings to fund future non-U.S. growth and expansion, and we do not anticipate remitting such earnings to the United States. While U.S. federal tax expense has been recognized as a result of the Tax Act, no deferred tax liabilities with respect to federal and state income taxes or foreign withholding taxes have been recognized.

Our quarterly provision for income taxes from continuing operations is calculated using an estimated annual effective income tax rate, which is adjusted for discrete items that occur during the reporting period. Our income taxes for the three months ended April 30, 2019 were negatively impacted by a $1.3 million reduction in prior year Work Opportunity Tax Credits (“WOTC”) for new hires and by certain reserves of $0.7 million, but were favorably impacted by $0.3 million of excess tax benefits related to the vesting of share-based compensation awards. Our income taxes for the six months ended April 30, 2019 were negatively impacted by a $1.4 million reduction in prior year WOTC and by certain reserves of $1.4 million, but were favorably impacted by $0.8 million of excess tax benefits related to the vesting of share-based compensation awards.

Our income taxes for the three months ended April 30, 2018 were favorably impacted by the reduction of the federal corporate income tax rate as a result of the Tax Act and by a discrete tax benefit of $2.0 million related to tax deductions on energy efficient government buildings, partially offset by a $1.5 million reduction in certain tax credits, including the prior year WOTC for new hires. Our income taxes for the six months ended April 30, 2018 were favorably impacted by a net discrete tax benefit of $21.7 million related to the enactment of the Tax Act, $2.3 million related to tax deductions on energy efficient government buildings, and $1.5 million of excess tax benefits related to the vesting of share-based compensation awards. These benefits were partially offset by a $1.5 million reduction in certain tax credits, including the prior year WOTC for new hires.