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Income Taxes
3 Months Ended
Dec. 29, 2018
Income Tax Disclosure [Abstract]  
Income Taxes
Income Taxes
Income tax expense for the three months ended December 29, 2018 was $11.9 million. Income tax expense for the three months ended December 30, 2017 was $127.5 million.
On December 22, 2017, the U.S. Tax Cuts & Jobs Act was enacted ("Tax Reform"). Due to the complexities in implementing Tax Reform, the SEC issued Staff Accounting Bulletin 118, which allowed the Company to record a tax expense when uncertainty or other factors may impact the final outcome. During fiscal year 2018, the Company made reasonable estimates related to the impact of Tax Reform and, in accordance with SAB118, recorded a net income tax expense of $85.9 million. The components of the tax expense included $61.2 million of U.S. federal and state taxes on deemed repatriation of historical undistributed foreign earnings, which are payable over an eight year period beginning in fiscal 2019, $21.8 million of foreign withholding taxes due to a change in the Company’s permanently reinvested assertion on foreign earnings that are payable upon repatriation to the U.S. and $2.9 million for unrecognized tax benefits related to the implementation of Tax Reform.
For the three months ended December 29, 2018, the Company recorded a $7.0 million increase to its income tax expense, inclusive of unrecognized tax benefits, as a result of additional proposed guidance issued by the U.S. Department of the Treasury on November 28, 2018, related to Tax Reform. The guidance related to the treatment of foreign taxes paid that impacted the tax on the deemed repatriation of historical undistributed foreign earnings. The Company's final tax expense recorded for Tax Reform was $92.9 million. Additionally, the effects of the Global Intangible Low-Taxed Income provision added by Tax Reform have been recorded in the three months ended December 29, 2018. The Company has elected to treat the income tax effects of this provision as a period cost.
The effective tax rates for the three months ended December 29, 2018 and December 30, 2017, were 34.9% and 439.2%, respectively. The effective tax rate for the three months ended December 29, 2018 decreased from the effective tax rate for the three months ended December 30, 2017, primarily due to the impact of Tax Reform.
For the three months ended December 29, 2018, the Company recorded an income tax benefit of $1.7 million primarily related to unrecognized tax benefits as the U.S. Department of the Treasury issued additional guidance for Tax Reform. The Company recognizes accrued interest and penalties on uncertain tax positions as a component of income tax expense. The amount of interest and penalties recorded for the three months ended December 29, 2018 was not material.
One or more uncertain tax positions may be settled within the next 12 months. Settlement of these matters is not expected to have a material effect on the Company's consolidated results of operations, financial position and cash flows. The Company is not currently under examination by taxing authorities in the U.S. or any foreign jurisdictions in which the Company operates.
The Company maintains valuation allowances when it is more likely than not that all or a portion of a net deferred tax asset will not be realized. During the three months ended December 29, 2018, the Company continued to record a full valuation allowance against its net deferred tax assets in certain jurisdictions within the EMEA segment and a partial valuation against its net deferred tax assets in certain jurisdictions within the AMER segment, as it was more likely than not that these assets would not be fully realized based primarily on historical performance. The Company will continue to provide a valuation allowance against its net deferred tax assets in each of the applicable jurisdictions going forward until it determines it is more likely than not that the deferred tax assets will be realized.