Income taxes



(in millions)	Fiscal 2019			Fiscal 2018			Fiscal 2017
Income (loss) before income taxes:
– US	$	(1,135.8	)	$	202.2		$	424.0
– Foreign	333.2			325.0			289.8
Total income (loss) before income taxes	$	(802.6	)	$	527.2		$	713.8

Current taxation:
– US	$	(55.2	)	$	35.9		$	137.6
– Foreign	15.8			6.1			3.9
Deferred taxation:
– US	(85.8		)	(34.8		)	28.1
– Foreign	(20.0		)	0.7			1.0
Total income tax expense (benefit)	$	(145.2	)	$	7.9		$	170.6

As the statutory rate of corporation tax in Bermuda is 0%, the differences between the US federal income tax rate and the effective tax rates for Signet have been presented below:



	Fiscal 2019		Fiscal 2018		Fiscal 2017
US federal income tax rates	21.0	%	35.0	%	35.0	%
US state income taxes	2.3	%	1.9	%	1.9	%
Differences between US federal and foreign statutory income tax rates	0.3	%	(1.0	)%	(0.2	)%
Expenditures permanently disallowable for tax purposes, net of permanent tax benefits	(0.8	)%	1.0	%	0.4	%
Disallowable transaction costs	—	%	0.4	%	0.1	%
Impact of global reinsurance arrangements	3.1	%	(8.1	)%	(5.4	)%
Impact of global financing arrangements	4.2	%	(11.4	)%	(8.2	)%
Benefit in current year taxes - the TCJ Act	—	%	(4.1	)%	—	%
Remeasurement of deferred taxes - the TCJ Act	—	%	(12.3	)%	—	%
Impairment of goodwill	(13.4	)%	—	%	—	%
Out of period adjustment	1.4	%	—	%	—	%
Other items	—	%	0.1	%	0.3	%
Effective tax rate	18.1	%	1.5	%	23.9	%

In Fiscal 2019, Signet’s effective tax rate was lower than the US federal income tax rate primarily due to the impact of nondeductible goodwill impairment charges partially offset by (i) Signet’s global reinsurance arrangement, (ii) Signet’s global financing arrangements utilized to fund the acquisition of Zale and (iii) an immaterial out of period adjustment resulting from an $11 million reduction to a deferred tax liability associated with the acquisition of Zale in May 2014. Signet’s future effective tax rate is largely dependent on changes in the geographic mix of income.

US Tax Reform

On December 22, 2017, the U.S. government enacted “An Act to Provide for Reconciliation Pursuant to Titles II and V of the Concurrent Resolution on the Budget for Fiscal Year 2018”, which is commonly referred to as “The Tax Cuts and Jobs Act” (the “TCJ Act”). The TCJ Act provides for comprehensive tax legislation that reduces the U.S. federal statutory corporate tax rate from 35.0 percent to 21.0 percent effective January 1, 2018, limits certain deductions, including limiting the deductibility of interest expense to 30% of U.S. Earnings Before Interest, Taxes, Depreciation and Amortization, broadens the U.S. federal income tax base, requires companies to pay a one-time repatriation tax on earnings of certain foreign subsidiaries that were previously tax deferred (“transition tax”), and creates new taxes on certain foreign sourced earnings. As we have a 52-53-week tax year ending the Saturday nearest October 31, the lower corporate income tax rate is administratively phased in, resulting in a blended U.S. federal statutory tax rate of approximately 23.4 percent for our tax year from October 29, 2017 through November 3, 2018, and 21.0 percent for our tax years thereafter.

Additionally, on December 22, 2017, the SEC issued Staff Accounting Bulletin 118 (“SAB 118”), expressing its views regarding the FASB's Accounting Standards Codification 740, Income Taxes, in the reporting period that includes the enactment date of the TCJ Act. SAB 118 recognizes that a registrant’s review of certain income tax effects of the TCJ Act may be incomplete at the time financial statements are issued for the reporting period that includes the enactment date, including interim periods therein. Specifically, SAB 118 allows a company to report provisional estimates in the reporting period that includes the enactment date if the company does not have the necessary information available, prepared, or fully analyzed for certain income tax effects of the TCJ Act. The provisional estimates would be adjusted during a measurement period not to exceed 12 months from the enactment date of the TCJ Act, at which time the accounting for the income tax effects of the TCJ Act is required to be completed. The Company adopted the provisions of SAB 118 with respect to the impact of the TCJ Act on its financial statements for the year ended February 3, 2018.

Accordingly, our income tax provision as of February 3, 2018, reflected provisional amounts with respect to Fiscal 2018 impacts of the TCJ Act on the effective tax rate as follows:



	Fiscal 2018
(in millions)	Income tax benefit (expense)
Net impact on remeasurement of US deferred tax assets and liabilities	$	64.7
Net impact of reduce US tax rate on income from October 29, 2017 through February 3, 2018	21.5
Net benefit of the TCJ Act	$	86.2

Consistent with SAB 118, the Company calculated and recorded reasonable estimates for the impact of the remeasurement of our existing US deferred tax assets and liabilities based on the rates at which they were expected to reverse in the future, of which the federal component is approximately 23.4 percent for reversals expected in the tax year from October 29, 2018 through November 3, 2018 and 21.0 percent thereafter. The provisional amount recorded related to the remeasurement of our deferred tax balance was a benefit of $64.7 million. The effect of the remeasurement was recorded in the fourth quarter of Fiscal 2018, consistent with the enactment date of the TCJ Act, and reflected in our provision for income taxes. The Company has completed its analysis during the fiscal year ended February 2, 2019 and no material adjustments have been recognized under SAB 118.

Deferred taxes

Deferred tax assets (liabilities) consisted of the following:



	February 2, 2019									February 3, 2018
(in millions)	Assets			(Liabilities)			Total			Assets			(Liabilities)			Total
Intangible assets	$	—		$	(63.8	)	$	(63.8	)	$	—		$	(130.9	)	$	(130.9	)
US property, plant and equipment	—			(68.2		)	(68.2		)	—			(65.2		)	(65.2		)
Foreign property, plant and equipment	6.5			—			6.5			6.2			—			6.2
Inventory valuation	—			(179.1		)	(179.1		)	—			(193.7		)	(193.7		)
Allowances for doubtful accounts	—			—			—			34.4			—			34.4
Revenue deferral	122.0			—			122.0			147.1			—			147.1
Derivative instruments	—			(1.3		)	(1.3		)	—			(0.3		)	(0.3		)
Straight-line lease payments	26.2			—			26.2			26.5			—			26.5
Deferred compensation	7.5			—			7.5			9.2			—			9.2
Retirement benefit obligations	—			(5.8		)	(5.8		)	—			(7.6		)	(7.6		)
Share-based compensation	3.5			—			3.5			4.4			—			4.4
Other temporary differences	46.7			—			46.7			47.1			—			47.1
Net operating losses and foreign tax credits	151.8			—			151.8			56.9			—			56.9
Value of capital losses	13.9			—			13.9			12.0			—			12.0
Total gross deferred tax assets (liabilities)	$	378.1		$	(318.2	)	$	59.9		$	343.8		$	(397.7	)	$	(53.9	)
Valuation allowance	(38.9		)	—			(38.9		)	(37.0		)	—			(37.0		)
Deferred tax assets (liabilities)	$	339.2		$	(318.2	)	$	21.0		$	306.8		$	(397.7	)	$	(90.9	)

Disclosed as:
Non-current assets							$	21.0								$	1.4
Non-current liabilities							—									(92.3		)
Deferred tax assets (liabilities)							$	21.0								$	(90.9	)

As of February 2, 2019, Signet had deferred tax assets associated with net operating loss carry forwards of $124.7 million, of which $32.1 million are subject to ownership change limitations rules under Section 382 of the Internal Revenue Code (“IRC”) and various US state regulations and expire between 2019 and 2037. Deferred tax assets associated with foreign tax credits also subject to Section 382 of the IRC total $13.7 million as of February 2, 2019, which expire between 2019 and 2024 and foreign net operating loss carryforwards of $13.4 million, which expire between 2019 and 2038. Additionally, Signet had foreign capital loss carry forward deferred tax assets of $11.6 million (Fiscal 2018: $12.0 million), which can be carried forward over an indefinite period and US capital loss carryforwards of $3.0 million which expire in 2022, both of which are only available to offset future capital gains.

The increase in the total valuation allowance in Fiscal 2019 was $1.9 million. The valuation allowance primarily relates to capital and operating loss carry forwards and foreign tax credits that, in the judgment of management, are not more likely than not to be realized.

Signet believes that it is more likely than not that deferred tax assets not subject to a valuation allowance as of February 2, 2019 will be offset where permissible by deferred tax liabilities or realized on future tax returns, primarily from the generation of future taxable income.

Uncertain tax positions

The following table summarizes the activity related to the Company’s unrecognized tax benefits for US federal, US state and non-US tax jurisdictions:



(in millions)	Fiscal 2019			Fiscal 2018			Fiscal 2017
Unrecognized tax benefits, beginning of period	$	12.0		$	12.0		$	11.4
Increases related to current year tax positions	2.5			2.3			2.4
Increases related to prior year tax positions	6.2			—			—
Lapse of statute of limitations	(2.4		)	(2.4		)	(1.9		)
Difference on foreign currency translation	(0.2		)	0.1			0.1
Unrecognized tax benefits, end of period	$	18.1		$	12.0		$	12.0

As of February 2, 2019, Signet had approximately $18.1 million of unrecognized tax benefits in respect to uncertain tax positions. The unrecognized tax benefits relate primarily to intercompany deductions including financing arrangements and intra-group charges which are subject to different and changing interpretations of tax law. Signet recognizes accrued interest and, where appropriate, penalties related to unrecognized tax benefits within income tax expense. As of February 2, 2019, Signet had accrued interest of $3.2 million and $0.7 million of accrued penalties. If all of these unrecognized tax benefits were settled in Signet’s favor, the effective income tax rate would be favorably impacted by $19.5 million.

Over the next twelve months management believes that it is reasonably possible that there could be a reduction of some or all of the unrecognized tax benefits as of February 2, 2019 due to settlement of the uncertain tax positions with the tax authorities.

Signet has business activity in all states within the US and files income tax returns for the US federal jurisdiction and all applicable states. Signet also files income tax returns in the UK, Canada and certain other foreign jurisdictions. Signet is subject to examinations by the US federal and state and Canadian tax authorities for tax years ending after November 1, 2011 and is subject to examination by the UK tax authority for tax years ending after February 1, 2014.