
16.	Income Taxes


(a)	Provision for Income Taxes

The provision for income taxes consists of the following (in millions):



Years Ended	July 25, 2015			July 26, 2014			July 27, 2013
Federal:
Current	$	1,583		$	1,672		$	601
Deferred	43			(383		)	152
	1,626			1,289			753
State:
Current	130			176			81
Deferred	(20		)	(64		)	48
	110			112			129
Foreign:
Current	530			692			599
Deferred	(46		)	(231		)	(237		)
	484			461			362
Total	$	2,220		$	1,862		$	1,244

Income before provision for income taxes consists of the following (in millions):



Years Ended	July 25, 2015		July 26, 2014		July 27, 2013
United States	$	3,570	$	2,734	$	3,716
International	7,631		6,981		7,511
Total	$	11,201	$	9,715	$	11,227

The items accounting for the difference between income taxes computed at the federal statutory rate and the provision for income taxes consist of the following:



Years Ended	July 25, 2015		July 26, 2014		July 27, 2013
Federal statutory rate	35.0	%	35.0	%	35.0	%
Effect of:
State taxes, net of federal tax benefit	0.8		0.5		0.8
Foreign income at other than U.S. rates	(15.2	)	(16.4	)	(16.4	)
Tax credits	(1.2	)	(0.7	)	(1.6	)
Domestic manufacturing deduction	(0.7	)	(0.9	)	(1.0	)
Nondeductible compensation	2.0		3.3		1.3
Tax audit settlement	—		—		(7.1	)
Other, net	(0.9	)	(1.6	)	0.1
Total	19.8	%	19.2	%	11.1	%

During fiscal 2015, the Tax Increase Prevention Act of 2014 reinstated the U.S. federal R&D tax credit for calendar year 2014 R&D expenses. As a result, the tax provision in fiscal 2015 included a tax benefit of $138 million related to the U.S. R&D tax credit, of which $78 million was attributable to fiscal 2014.

During fiscal 2013, the Internal Revenue Service (IRS) and the Company settled all outstanding items related to the audit of the Company’s federal income tax returns for the fiscal years ended July 27, 2002 through July 28, 2007. As a result of the settlement, the Company recognized a net benefit to the provision for income taxes of $794 million. In addition, the American Taxpayer Relief Act reinstated the U.S. federal R&D credit through December 2013, retroactive to January 1, 2012. As a result, the tax provision in fiscal 2013 included a tax benefit of $184 million related to the U.S. federal R&D tax credit, of which $72 million was attributable to fiscal 2012.

U.S. income taxes and foreign withholding taxes associated with the repatriation of earnings of foreign subsidiaries were not provided for on a cumulative total of $58.0 billion of undistributed earnings for certain foreign subsidiaries as of the end of fiscal 2015. The Company intends to reinvest these earnings indefinitely in its foreign subsidiaries. If these earnings were distributed to the United States in the form of dividends or otherwise, or if the shares of the relevant foreign subsidiaries were sold or otherwise transferred, the Company would be subject to additional U.S. income taxes (subject to an adjustment for foreign tax credits) and foreign withholding taxes. Determination of the amount of unrecognized deferred income tax liability related to these earnings is not practicable.

As a result of certain employment and capital investment actions, the Company’s income in certain foreign countries is subject to reduced tax rates and in some cases is wholly exempt from taxes. A portion of these incentives expired at the end of fiscal 2015. The majority of the remaining tax incentives will expire at the end of fiscal 2025. The gross income tax benefit attributable to tax incentives was estimated to be $1.4 billion ($0.28 per diluted share) in fiscal 2015, of which approximately $0.5 billion ($0.10 per diluted share) is based on tax incentives that expired at the end of fiscal 2015. As of the end of fiscal 2014 and fiscal 2013, the gross income tax benefits attributable to tax incentives were estimated to be $1.3 billion and $1.4 billion ($0.25 and $0.26 per diluted share) for the respective years. The gross income tax benefits were partially offset by accruals of U.S. income taxes on undistributed earnings.

Unrecognized Tax Benefits

The aggregate changes in the balance of gross unrecognized tax benefits were as follows (in millions):



Years Ended	July 25, 2015			July 26, 2014			July 27, 2013
Beginning balance	$	1,938		$	1,775		$	2,819
Additions based on tax positions related to the current year	276			262			138
Additions for tax positions of prior years	137			64			187
Reductions for tax positions of prior years	(30		)	(13		)	(1,027		)
Settlements	(165		)	(17		)	(199		)
Lapse of statute of limitations	(127		)	(133		)	(143		)
Ending balance	$	2,029		$	1,938		$	1,775

As of July 25, 2015, $1.7 billion of the unrecognized tax benefits would affect the effective tax rate if realized. During fiscal 2015 the Company recognized $27 million of net interest expense and $3 million of penalties. During fiscal 2014, the Company recognized $29 million of net interest expense and $8 million of penalties. During fiscal 2013, the Company recognized $115 million of net interest expense and $2 million of penalties. The Company’s total accrual for interest and penalties was $274 million, $304 million, and $268 million as of the end of fiscal 2015, 2014, and 2013, respectively. The Company is no longer subject to U.S. federal income tax audit for returns covering tax years through fiscal 2007. With limited exceptions, the Company is no longer subject to foreign, state, or local income tax audits for returns covering tax years through fiscal 2002.

The Company regularly engages in discussions and negotiations with tax authorities regarding tax matters in various jurisdictions. The Company believes it is reasonably possible that certain federal, foreign, and state tax matters may be concluded in the next 12 months. Specific positions that may be resolved include issues involving transfer pricing and various other matters. The Company estimates that the unrecognized tax benefits at July 25, 2015 could be reduced by approximately $900 million in the next 12 months, a portion of which could increase earnings.


(b)	Deferred Tax Assets and Liabilities

The following table presents the breakdown between current and noncurrent net deferred tax assets (in millions):



	July 25, 2015			July 26, 2014
Deferred tax assets—current	$	2,915		$	2,808
Deferred tax liabilities—current	(212		)	(134		)
Deferred tax assets—noncurrent	1,648			1,700
Deferred tax liabilities—noncurrent	(246		)	(369		)
Total net deferred tax assets	$	4,105		$	4,005

The components of the deferred tax assets and liabilities are as follows (in millions):



	July 25, 2015			July 26, 2014
ASSETS
Allowance for doubtful accounts and returns	$	417		$	464
Sales-type and direct-financing leases	266			231
Inventory write-downs and capitalization	345			307
Investment provisions	112			212
IPR&D, goodwill, and purchased intangible assets	134			135
Deferred revenue	1,795			1,689
Credits and net operating loss carryforwards	746			796
Share-based compensation expense	520			661
Accrued compensation	467			496
Other	670			676
Gross deferred tax assets	5,472			5,667
Valuation allowance	(84		)	(114		)
Total deferred tax assets	5,388			5,553
LIABILITIES
Purchased intangible assets	(950		)	(1,229		)
Depreciation	(143		)	(48		)
Unrealized gains on investments	(175		)	(245		)
Other	(15		)	(26		)
Total deferred tax liabilities	(1,283		)	(1,548		)
Total net deferred tax assets	$	4,105		$	4,005

As of July 25, 2015, the Company’s federal, state, and foreign net operating loss carryforwards for income tax purposes were $204 million, $536 million, and $697 million, respectively. A significant amount of the federal net operating loss carryforwards relates to acquisitions and, as a result, is limited in the amount that can be recognized in any one year. If not utilized, the federal net operating loss will begin to expire in fiscal 2018, and the state and foreign net operating loss carryforwards will begin to expire in fiscal 2018 and 2016, respectively. The Company has provided a valuation allowance of $68 million for deferred tax assets related to foreign net operating losses that are not expected to be realized.

As of July 25, 2015, the Company’s federal, state, and foreign tax credit carryforwards for income tax purposes were approximately $7 million, $700 million, and $26 million, respectively. The federal and foreign tax credit carryforwards will begin to expire in fiscal 2017 and 2018, respectively. The majority of state and foreign tax credits can be carried forward indefinitely. The Company has provided a valuation allowance of $16 million for deferred tax assets related to state and foreign tax credits that are not expected to be realized.