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Income Taxes
12 Months Ended
Jun. 30, 2014
Income Tax Expense (Benefit), Continuing Operations [Abstract]  
Income Taxes
INCOME TAXES
Domestic and foreign income (loss) before income taxes for the three years ended June 30 were as follows:
(in thousands)
 
2014
 
2013
 
2012
Domestic
 
$
98,154

 
$
35,792

 
$
18,347

Foreign
 
89,707

 
97,358

 
61,359

 
 
$
187,861

 
$
133,150

 
$
79,706


Provisions for income taxes for the three years ended June 30 were as follows:
(in thousands)
 
2014
 
2013
 
2012
Current:
 
 
 
 
 
 
Federal
 
$
27,264

 
$
6,279

 
$
8,054

State
 
9,456

 
2,565

 
1,010

Foreign
 
33,242

 
26,651

 
9,608

 
 
69,962

 
35,495

 
18,672

Deferred:
 
 
 
 
 
 
Federal
 
4,001

 
7,650

 
2,447

State
 
(905
)
 
(2,113
)
 
(869
)
Foreign
 
(14,291
)
 
(3,854
)
 
(3,702
)
 
 
(11,195
)
 
1,683

 
(2,124
)
 
 
$
58,767

 
$
37,178

 
$
16,548


Our consolidated effective income tax rate differed from the U.S. federal statutory income tax rate as set forth below:
(in thousands)
 
2014
 
%
 
2013
 
%
 
2012
 
%
Income tax expense computed at the federal statutory rate
 
$
65,751

 
35.0
 %
 
$
46,602

 
35.0
 %
 
$
27,897

 
35.0
 %
State income taxes, net of federal benefit
 
5,419

 
2.9
 %
 
1,914

 
1.4
 %
 
(232
)
 
(0.3
)%
Foreign rate differential
 
(4,857
)
 
(2.6
)%
 
(7,960
)
 
(6.0
)%
 
(6,539
)
 
(8.2
)%
Change in valuation allowances
 
(491
)
 
(0.3
)%
 
(4,708
)
 
(3.5
)%
 
1,630

 
2.0
 %
Change in reserves
 
(5,193
)
 
(2.8
)%
 
394

 
0.3
 %
 
(7,655
)
 
(9.6
)%
Research and development
 
(3,284
)
 
(1.7
)%
 
(2,986
)
 
(2.2
)%
 
(2,734
)
 
(3.4
)%
Non-deductible losses
 
69

 
 %
 
440

 
0.3
 %
 
678

 
0.9
 %
Other non-deductible expenses
 
1,315

 
0.7
 %
 
2,074

 
1.6
 %
 
393

 
0.5
 %
Adjustment of net operating losses
 

 
 %
 
608

 
0.5
 %
 
2,243

 
2.8
 %
Statutory tax rate changes
 
(623
)
 
(0.3
)%
 
798

 
0.5
 %
 
(1,047
)
 
(1.3
)%
Other, net
 
661

 
0.4
 %
 
2

 
 %
 
1,914

 
2.4
 %
 
 
$
58,767

 
31.3
 %
 
$
37,178

 
27.9
 %
 
$
16,548

 
20.8
 %

Provision has not been made for U.S. or additional foreign taxes on undistributed earnings of foreign subsidiaries as those earnings are indefinitely reinvested. Undistributed earnings of foreign subsidiaries that are indefinitely reinvested are approximately $423.0 million and $368.0 million at June 30, 2014 and June 30, 2013, respectively. Due to the complexities associated with this hypothetical calculation, it is not practicable to estimate the unrecognized deferred tax liability on the earnings that are indefinitely reinvested in foreign operations.
Significant components of our net deferred tax assets (liabilities) as of June 30, 2014 and June 30, 2013 were as follows:
(in thousands)
 
2014
 
2013
Deferred tax assets:
 
 
 
 
U.S. loss carryforwards
 
$
1,764

 
$
1,981

Foreign loss carryforwards
 
2,814

 
6,240

Accrued expenses
 
38,915

 
35,340

Tax credit carryforwards
 
5,711

 
14,559

Provision for losses on receivables
 
920

 
1,161

Deferred compensation
 
8,219

 
7,517

Deferred revenue
 
12,698

 
8,949

Intercompany loans
 
2,752

 
2,765

Other
 
3,597

 
1,168

Gross deferred tax assets
 
77,390

 
79,680

Deferred tax asset valuation allowance
 
(5,318
)
 
(6,023
)
Total deferred tax assets
 
72,072

 
73,657

Deferred tax liabilities:
 
 
 
 
Property and equipment
 
(6,521
)
 
(5,606
)
Revenue recognition
 
(17,601
)
 
(26,537
)
Intangible assets
 
(35,372
)
 
(38,186
)
Other
 
(1,038
)
 
(2,491
)
Total deferred tax liabilities
 
(60,532
)
 
(72,820
)
Net deferred tax assets
 
$
11,540

 
$
837


The net deferred tax assets and liabilities included in the consolidated balance sheets as of June 30, 2014 and June 30, 2013 were as follows:
(in thousands)
 
2014
 
2013
Current deferred tax assets
 
$
54,061

 
$
44,236

Non-current deferred tax assets
 
6,669

 
8,556

Current deferred tax liabilities
 
(16,592
)
 
(16,512
)
Non-current deferred tax liabilities
 
(32,598
)
 
(35,443
)
 
 
$
11,540

 
$
837


At June 30, 2014, federal, state and foreign loss carryforwards of $2.8 million, $35.8 million and $15.8 million, respectively, were available to offset future liabilities for income taxes. The federal net operating losses expire in the years 2025 through 2034. Included in the state loss carryforwards is $3.7 million attributable to deductions from the exercise of equity awards. The benefit from these deductions will be recorded as a credit to additional paid-in capital if and when realized through a reduction of taxes paid in cash. Use of these loss carryforwards is limited based on the future income of certain subsidiaries. The state net operating losses expire in the years 2016 through 2033. Of the non-U.S. loss carryforwards, $4.8 million will expire between 2015 and 2034; the remainder does not expire. We also have U.S. foreign tax credit carryforwards of $28.0 million, which expire in the years 2018 through 2024. Included in the U.S. foreign tax credit carryforwards is $15.4 million attributable to deductions from the exercise of equity awards. The benefit from these credits will be recorded as a credit to additional paid-in capital if and when realized through a reduction of taxes paid in cash.
A valuation allowance has been established for certain future income tax benefits related to loss carryforwards and temporary tax adjustments based on an assessment that it is more likely than not that these benefits will not be realized. The decrease in the valuation allowance in Fiscal Year 2013 was principally due to improved profitability in various jurisdictions.
As of June 30, 2014, we had $41.5 million of gross unrecognized tax benefits of which $25.4 million would impact the effective tax rate if recognized. As of June 30, 2013, we had $46.6 million of gross unrecognized tax benefits of which $31.0 million would impact the effective tax rate if recognized. This reserve primarily relates to exposures for income tax matters such as changes in the jurisdiction in which income is taxable.
Unrecognized tax benefits represent favorable positions we have taken, or expect to take, on tax returns. These positions have reduced, or are expected to reduce, our income tax liability on our tax returns and financial statements. As a result of the uncertainty associated with these positions, we have established a liability that effectively reverses the previous recognition of the tax benefits, making them “unrecognized.” Our unrecognized income tax benefits, excluding accrued interest and penalties, are as follows:
(in thousands)
 
2014
 
2013
 
2012
Balance at beginning of year
 
$
46,591

 
$
53,813

 
$
62,211

Additions related to tax positions in prior years
 
792

 

 
4,433

Reductions related to tax positions in prior years
 
(1,115
)
 
(2,869
)
 
(1,898
)
Reductions related to settlements with tax authorities
 

 

 
(477
)
Reductions related to the expiration of statutes
 
(5,630
)
 
(4,662
)
 
(6,789
)
Currency translation adjustments
 
833

 
309

 
(3,667
)
Balance at end of year
 
$
41,471

 
$
46,591

 
$
53,813


As of June 30, 2014, we anticipate that the liability for unrecognized tax benefits for uncertain tax positions could change by up to $6.6 million in the next twelve months primarily as a result of the expiration of statutes of limitation and settlement with tax authorities. This change is composed primarily of reserves associated with the jurisdiction in which income is taxable.
We recognize interest and penalties related to income tax matters in income tax expense. As of June 30, 2014 and June 30, 2013, interest and penalties of $5.5 million and $5.0 million, respectively, were included in our liability for unrecognized tax benefits. For Fiscal Years 2014, 2013 and 2012, an expense of $0.3 million, and a benefit of $0.9 million and $2.1 million, respectively, was recorded for interest and penalties related to tax matters.
We are subject to U.S. federal income tax, as well as income tax in multiple state, local and foreign jurisdictions. All material state and local income tax matters through 2005 have been concluded. All material federal income tax matters have been concluded through 2005. Substantially all material foreign income tax matters have been concluded for all years through 2000.