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Income Taxes
3 Months Ended
Jan. 02, 2016
Income Tax Disclosure [Abstract]  
Income Taxes
Income Taxes
In the first quarter of 2016, our effective tax rate was (22)% on a pre-tax loss of $19.5 million, compared to a provision of 12% on pre-tax income of $34.4 million in the first quarter of 2015. In the first quarter of 2016 and 2015, our effective tax rate was lower than the 35% statutory federal income tax rate due to our corporate structure in which our foreign taxes are at a net effective tax rate lower than the U.S. rate. A significant amount of our foreign earnings is generated by our subsidiaries organized in Ireland. In 2016 and 2015, the foreign rate differential predominantly relates to these Irish earnings. Our foreign rate differential in 2016 and 2015 includes a rate benefit from a business realignment completed on September 30, 2014 in which intellectual property was transferred between two wholly-owned foreign subsidiaries. The realignment allows us to more efficiently manage the distribution of our products to European customers. This realignment resulted in a tax benefit of approximately $3 million and $4 million in the first quarter of 2016 and 2015, respectively. Additionally, in 2016 and 2015 our provision reflects a tax benefit of $2.6 million and $2.1 million respectively, related to a retroactive extension of the U.S. research and development tax credit enacted in the first quarter of 2016 and 2015. In 2016 and 2015, this benefit was offset by a corresponding provision to increase our U.S. valuation allowance.
As of January 2, 2016 and September 30, 2015, we had unrecognized tax benefits of $14.4 million and $14.1 million, respectively. If all of our unrecognized tax benefits as of January 2, 2016 were to become recognizable in the future, we would record a benefit to the income tax provision of $12.8 million which would be partially offset by an increase in the U.S. valuation allowance of $4.6 million
Although we believe our tax estimates are appropriate, the final determination of tax audits and any related litigation could result in favorable or unfavorable changes in our estimates. We believe it is reasonably possible that within the next 12 months the amount of unrecognized tax benefits related to the resolution of multi-jurisdictional tax positions could be reduced by up to $4 million as audits close and statutes of limitations expire.