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Income Taxes
6 Months Ended
Apr. 30, 2021
Income Tax Disclosure [Abstract]  
Income Taxes Income Taxes
For interim income tax reporting we estimate our annual effective tax rate and apply it to our year to date ordinary income (loss). Tax jurisdictions with a projected full year loss for which a tax benefit cannot be realized are excluded. Our annual effective tax rate is primarily impacted by jurisdictions that continue to be in a valuation allowance where tax benefits are not recognized. The tax effects of unusual or infrequently occurring items, including changes in judgment about valuation allowances and effects of changes in tax laws or rates, are reported in the interim period in which they occur.
For the three and six months ended April 30, 2021, we recognized an income tax expense of $51 million and $33 million, respectively, compared to income tax expense of $7 million and $2 million for the respective prior year periods. The change in tax is primarily due to the increase in income before income taxes and earnings and/or losses for which no tax expense or benefit can be recognized due to valuation allowances. Other year over year differences for the second quarter and first half of 2021 include geographical mix and certain discrete items, primarily related to the change in value of the U.S. dollar resulting in an income tax expense of $19 million and $23 million for the three and six months ended April 30, 2021, respectively.
We have open tax years back to 2001 with various significant taxing jurisdictions, including the U.S., Canada, Mexico, and Brazil. In connection with the examination of tax returns, contingencies may arise that generally result from differing interpretations of applicable tax laws and regulations as they relate to the amount, timing, or inclusion of revenues or expenses in taxable income, or the sustainability of tax credits to reduce income taxes payable. In our 2018 fiscal year, we received a favorable ruling from the Tribunal Regional Federal da 4 (the Fourth Regional Federal Court in Brazil, the "Brazilian Fourth Court") in connection with certain indirect federal taxes (PIS and COFINS) credits in Brazil. In 2020 we determined that it was probable to receive the credits, which were recognized within our 2020 fiscal year results. We have a pending similar case in the Brazilian Fourth Court. The Receita Federal, a tax authority in Brazil, filed a Motion of Clarification on a leading case with the Supremo Tribunal Federal (the "Brazilian Supreme Court"). In May 2021, the Brazilian Supreme Court ruled in favor of the taxpayer in this leading case related to the calculation of the credits and the scope of the tax years applicable for credits. As a result of that ruling, we determined that it was probable to receive a benefit as a result of or connection with our pending case with the Brazilian Fourth Court and recorded an estimated $28 million benefit in Sales of manufactured products, net and a $2 million charge in Selling, General & Administrative expenses in our Consolidated Statements of Operations in our Global Operations segment, (translated into US dollars as of April 30, 2021) associated with tax years 2002 to 2020. Timing on realization of PIS and COFINS credits is dependent upon the timing of administrative approvals and generation of federal tax liabilities eligible for offset or sale. Additional contingencies that would result in tax recoveries may be resolved in future periods which could be material.
We have evaluated the need to maintain a valuation allowance for deferred tax assets based on our assessment of whether it is more-likely-than-not that deferred tax benefits will be realized through the generation of future taxable income. We continue to maintain a valuation allowance on the majority of our U.S. deferred tax assets as well as certain foreign deferred tax assets that we believe, on a more-likely-than-not basis, will not be realized based on our analysis of the relevant facts and circumstances. For all remaining deferred tax assets, while we believe that it is more-likely-than-not that they will be realized, we believe that it is reasonably possible that additional deferred tax asset valuation allowances could be required in the next twelve months.