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Income Taxes
 12 Months Ended
Sep. 30, 2023
Income Tax Disclosure [Abstract]  
Income Taxes Income Taxes
The domestic and foreign components of income (loss) before income tax expense for fiscal 2023, 2022 and 2021 were as follows (in thousands): 
202320222021
U.S.$(84,557)$(64,267)$(33,409)
Foreign245,570 222,570 193,820 
$161,013 $158,303 $160,411 
Income tax expense (benefit) for fiscal 2023, 2022 and 2021 were as follows (in thousands): 
202320222021
Current:
Federal$24,779 $12,506 $9,217 
State302 386 524 
Foreign19,276 17,968 15,146 
44,357 30,860 24,887 
Deferred:
Federal(21,098)(9,931)(1,153)
State(1,371)(315)1 
Foreign31 (554)(2,236)
(22,438)(10,800)(3,388)
$21,919 $20,060 $21,499 
The following is a reconciliation of the federal statutory income tax rate to the effective income tax rates reflected in the Consolidated Statements of Comprehensive Income for fiscal 2023, 2022 and 2021: 
202320222021
Federal statutory income tax rate21.0 %21.0 %21.0 %
(Decrease) increase resulting from:
Foreign tax rate differences(23.8)(23.2)(20.3)
Withholding tax on dividends0.4 2.2 2.9 
Permanent differences(1.3)(0.8)(0.6)
Excess tax benefits related to share-based compensation(1.1)(1.4)(0.9)
Global intangible low-taxed income ("GILTI")13.1 10.4 6.4 
Audit settlements— 3.7 5.0 
Non-deductible compensation2.8 2.5 3.8 
Valuation allowances3.5 (1.7)(3.7)
Tax credits, net(2.1)(1.9)— 
Other, net1.1 1.9 (0.2)
Effective income tax rate13.6 %12.7 %13.4 %
The effective tax rate for fiscal 2023 was higher than the effective tax rate for fiscal 2022 primarily due to the GILTI impact of the research and development capitalization requirement and the geographic distribution of worldwide earnings. The effective tax rate for fiscal 2022 was lower than the effective tax rate for fiscal 2021 primarily due to claiming a U.S. Research & Development tax credit and the geographic distribution of worldwide earnings.
During fiscal 2023, the Company recorded a $5.7 million increase to its valuation allowance due to continuing losses in various jurisdictions.
During fiscal 2022, the Company recorded a $2.8 million decrease to its valuation allowance primarily due to a net decrease of the valuation allowance in the EMEA segment driven by the release of the valuation allowance against the net deferred tax assets of a foreign subsidiary. This is partially offset by continuing losses in certain jurisdictions within the AMER segment.
During fiscal 2021, the Company recorded a $5.9 million decrease to its valuation allowance primarily due to a net decrease of the valuation allowance in the EMEA segment driven by the release of the valuation allowance against the net deferred tax assets of a foreign subsidiary. This is partially offset by continuing losses in certain jurisdictions within the AMER segment.
The components of the net deferred income tax assets as of September 30, 2023 and October 1, 2022, were as follows (in thousands):
20232022
Deferred income tax assets:
Loss/credit carryforwards$27,810 $24,575 
Inventories24,183 21,869 
Accrued employee benefits14,548 17,224 
Advanced payments from customers25,291 7,257 
Lease obligations17,520 17,427 
Research and development capitalization8,602 — 
Other8,556 6,408 
Total gross deferred income tax assets126,510 94,760 
Less valuation allowances(31,949)(25,562)
Deferred income tax assets94,561 69,198 
Deferred income tax liabilities:
Property, plant and equipment21,931 19,878 
Right-of-use assets10,539 10,538 
Tax on unremitted earnings3,851 6,034 
Deferred income tax liabilities36,321 36,450 
 Net deferred income tax assets$58,240 $32,748 
During fiscal 2023, the Company’s valuation allowance increased by $6.4 million, including the impact of foreign exchange movement. This increase is the result of increases to the valuation allowances against the net deferred tax assets in the EMEA, AMER, and APAC regions of $2.4 million, $1.2 million and $2.8 million, respectively.
As of September 30, 2023, the Company had approximately $184.2 million of pre-tax state net operating loss carryforwards that expire between fiscal 2024 and 2044. Certain state net operating losses have a full valuation allowance against them. The Company also had approximately $61.9 million of pre-tax foreign net operating loss carryforwards that expire between fiscal 2027 and 2034 or are indefinitely carried forward. Certain foreign net operating losses have a full valuation allowance against them.
The Company has been granted a tax holiday for a foreign subsidiary in the APAC segment. This tax holiday will expire on December 31, 2034, and is subject to certain conditions with which the Company expects to continue to comply. During fiscal 2023, 2022 and 2021, the tax holiday resulted in tax reductions, net of the impact of the GILTI provisions of U.S. Tax Reform, of approximately $25.9 million ($0.94 per basic share, $0.92 per diluted share), $35.3 million ($1.27 per basic share, $1.24 per diluted share) and $34.4 million ($1.20 per basic share, $1.18 per diluted share), respectively.
The Company does not provide for taxes that would be payable if certain undistributed earnings of foreign subsidiaries were remitted because the Company considers these earnings to be permanently reinvested. The deferred tax liability that has not been recorded for these earnings was approximately $14.5 million as of September 30, 2023.
The Company has approximately $14.0 million of uncertain tax benefits as of September 30, 2023. The Company has classified these amounts in the Consolidated Balance Sheets as "Other liabilities" (non-current) in the amount of $13.6 million and an offset to "Deferred income taxes" (non-current asset) in the amount of $0.4 million as the payment is not anticipated within one year.
The following is a reconciliation of the beginning and ending amounts of unrecognized income tax benefits for the indicated fiscal years (in thousands):
202320222021
Balance at beginning of fiscal year$8,998 $4,635 $2,096 
Gross increases for tax positions of prior years3,778 2,421 623 
Gross increases for tax positions of the current year2,105 2,531 2,161 
Gross decreases for tax positions of prior years(931)(589)(245)
Balance at end of fiscal year$13,950 $8,998 $4,635 
The amount of unrecognized tax benefits that, if recognized, would impact the effective tax rate is $13.6 million and $8.6 million for the fiscal years ended September 30, 2023 and October 1, 2022, respectively.
The Company recognizes accrued interest and penalties related to unrecognized tax benefits in income tax expense. The total accrued penalties and net accrued interest with respect to income taxes was approximately $1.1 million as of September 30, 2023, approximately $0.5 million as of October 1, 2022 and approximately $0.5 million as of October 2, 2021. The Company recognized $0.6 million of expense for accrued penalties and net accrued interest in the Consolidated Statements of Comprehensive Income for fiscal 2023, $0.3 million for fiscal 2022 and less than $0.1 million in fiscal 2021.
It is possible that a number of 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 files income tax returns, including returns for its subsidiaries, with federal, state, local and foreign taxing jurisdictions. The following tax years remain subject to examination by the respective major tax jurisdictions:
Jurisdiction  Fiscal Years
China2019-2023
Germany2019-2023
Malaysia2019-2023
Mexico2019-2023
Romania2020-2023
Thailand2021-2023
United Kingdom2020-2023
United States
  Federal2015, 2017, 2018, 2020-2023
  State2003-2006, 2009-2023