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Income Taxes
12 Months Ended
Jul. 25, 2020
Income Tax Disclosure [Abstract]  
Income Taxes
Income Taxes
(a)
Provision for Income Taxes
The provision for income taxes consists of the following (in millions):
Years Ended
July 25, 2020
 
July 27, 2019
 
July 28, 2018
Federal:
 
 
 
 
 
Current
$
1,101

 
$
1,760

 
$
9,900

Deferred
(374
)
 
(84
)
 
1,156

 
727

 
1,676

 
11,056

State:
 
 
 
 
 
Current
264

 
302

 
340

Deferred
287

 
(2
)
 
(232
)
 
551

 
300

 
108

Foreign:
 
 
 
 
 
Current
1,429

 
1,238

 
1,789

Deferred
49

 
(264
)
 
(24
)
 
1,478

 
974

 
1,765

Total
$
2,756

 
$
2,950

 
$
12,929


Income before provision for income taxes consists of the following (in millions):
Years Ended
July 25, 2020
 
July 27, 2019
 
July 28, 2018
United States
$
7,534

 
$
7,611

 
$
3,765

International
6,436

 
6,960

 
9,274

Total
$
13,970

 
$
14,571

 
$
13,039


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, 2020
 
July 27, 2019
 
July 28, 2018
Federal statutory rate
21.0
 %
 
21.0
 %
 
27.0
 %
Effect of:
 
 
 
 
 
State taxes, net of federal tax benefit
3.5

 
2.0

 
0.6

Foreign income at other than U.S. rates
(1.5
)
 
(4.5
)
 
(5.2
)
Tax credits
(0.9
)
 
(1.7
)
 
(2.5
)
Foreign-derived intangible income deduction
(2.6
)
 
(1.3
)
 

Domestic manufacturing deduction

 

 
(0.5
)
Stock-based compensation
(0.1
)
 
(0.6
)
 
(0.1
)
Impact of the Tax Act

 
6.1

 
80.1

Other, net
0.3

 
(0.8
)
 
(0.2
)
Total
19.7
 %

20.2
 %
 
99.2
 %
During fiscal 2018 and 2019, we recorded a total tax charge as a result of the Tax Act of $11.3 billion, consisting of $9.0 billion of tax expense for the U.S. transition tax on accumulated earnings of foreign subsidiaries, $1.2 billion of foreign withholding tax and $1.1 billion of tax expense for DTA re-measurement.
During fiscal 2020, the Internal Revenue Service (IRS) and Cisco settled all outstanding items related to the audit of our federal income tax returns for the fiscal year ended July 30, 2011 through July 27, 2013. As a result of the settlement, we recognized a net benefit to the provision for income taxes of $102 million, which included a reduction in interest expense of $4 million. We are no longer subject to U.S. federal tax audit through fiscal 2013.
Foreign taxes associated with the repatriation of earnings of foreign subsidiaries were not provided on a cumulative total of $6.8 billion of undistributed earnings for certain foreign subsidiaries as of the end of fiscal 2020. We intend to reinvest these earnings indefinitely in such foreign subsidiaries. If these earnings were distributed in the form of dividends or otherwise, or if the shares
of the relevant foreign subsidiaries were sold or otherwise transferred, we could be subject to additional foreign taxes. The amount of potential unrecognized deferred income tax liability related to these earnings is approximately $706 million.
As a result of certain employment and capital investment actions, our income in certain foreign countries was subject to reduced tax rates. The tax incentives expired at the end of fiscal 2019. As of the end of fiscal 2019 and 2018, the gross income tax benefits attributable to tax incentives were estimated to be $0.3 billion and $0.9 billion ($0.08 and $0.19 per diluted share) for the respective years. The gross income tax benefits were partially offset by accruals of U.S. income taxes on foreign earnings.
Unrecognized Tax Benefits
The aggregate changes in the balance of gross unrecognized tax benefits were as follows (in millions):
Years Ended
July 25, 2020
 
July 27, 2019
 
July 28, 2018
Beginning balance
$
1,925

 
$
2,000

 
$
1,973

Additions based on tax positions related to the current year
188

 
185

 
251

Additions for tax positions of prior years
554

 
84

 
84

Reductions for tax positions of prior years
(136
)
 
(283
)
 
(129
)
Settlements
(4
)
 
(38
)
 
(124
)
Lapse of statute of limitations
(9
)
 
(23
)
 
(55
)
Ending balance
$
2,518

 
$
1,925

 
$
2,000


As of July 25, 2020, $2.2 billion of the unrecognized tax benefits would affect the effective tax rate if realized. During fiscal 2020, we recognized $104 million of net interest expense and increased our unrecognized tax benefits for prior year tax positions by $554 million to reflect expected settlement positions in on-going U.S. federal, state, and foreign income tax return examinations. We recognized net interest expense of $30 million and $10 million, respectively, during fiscal 2019 and 2018. Our net penalty expense for fiscal 2020, 2019 and 2018 was not material. Our total accrual for interest and penalties was $340 million, $220 million, and $180 million as of the end of fiscal 2020, 2019, and 2018, respectively. We are no longer subject to U.S. federal income tax audit for returns covering tax years through fiscal 2013. We are no longer subject to foreign or state income tax audits for returns covering tax years through fiscal 1999 and fiscal 2008, respectively.
We regularly engage in discussions and negotiations with tax authorities regarding tax matters in various jurisdictions. We believe 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. We estimate that the unrecognized tax benefits at July 25, 2020 could be reduced by $150 million in the next 12 months.
(b)
Deferred Tax Assets and Liabilities
The following table presents the breakdown for net deferred tax assets (in millions):
 
July 25, 2020
 
July 27, 2019
Deferred tax assets
$
3,990

 
$
4,065

Deferred tax liabilities
(81
)
 
(95
)
Total net deferred tax assets
$
3,909

 
$
3,970


The following table presents the components of the deferred tax assets and liabilities (in millions):
 
July 25, 2020
 
July 27, 2019
ASSETS
 
 
 
Allowance for doubtful accounts and returns
$
110

 
$
127

Sales-type and direct-financing leases
179

 
176

Inventory write-downs and capitalization
350

 
409

Deferred foreign income
253

 

IPR&D, goodwill, and purchased intangible assets
1,289

 
1,427

Deferred revenue
1,182

 
1,150

Credits and net operating loss carryforwards
1,105

 
1,241

Share-based compensation expense
135

 
164

Accrued compensation
353

 
342

Lease liabilities
240

 

Other
571

 
419

Gross deferred tax assets
5,767

 
5,455

Valuation allowance
(700
)
 
(457
)
Total deferred tax assets
5,067

 
4,998

LIABILITIES
 
 
 
Purchased intangible assets
(577
)
 
(705
)
Depreciation
(179
)
 
(141
)
Unrealized gains on investments
(119
)
 
(70
)
ROU lease assets
(222
)
 

Other
(61
)
 
(112
)
Total deferred tax liabilities
(1,158
)
 
(1,028
)
Total net deferred tax assets
$
3,909

 
$
3,970

As of July 25, 2020, our federal, state, and foreign net operating loss carryforwards for income tax purposes were $405 million, $1.2 billion, and $644 million, respectively. A significant amount of the 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 carryforwards will begin to expire in fiscal 2022, and the state and foreign net operating loss carryforwards will begin to expire in fiscal 2021. We have provided a valuation allowance of $98 million for deferred tax assets related to foreign net operating losses that are not expected to be realized.
As of July 25, 2020, our federal, state, and foreign tax credit carryforwards for income tax purposes were approximately $10 million, $1.2 billion, and $5 million, respectively. The federal tax credit carryforwards will begin to expire in fiscal 2021. The majority of state and foreign tax credits can be carried forward indefinitely. We have provided a valuation allowance of $541 million for deferred tax assets related to state and foreign tax credits that are not expected to be realized.