
Provision (benefit) for taxes:
U.S. Federal:
Current	$	(5.8)		$	(3.8)		$	(19.7)
Deferred	(16.3)			252.3			(25.8)
	(22.1)			248.5			(45.5)
U.S. State:
Current	0.8			5.1			5.0
Deferred	7.1			(0.7)			(3.6)
	7.9			4.4			1.4
Foreign:
Current	62.2			49.2			57.0
Deferred	(43.6)			(471.8)			(18.2)
	18.6			(422.6)			38.8
Income tax provision (benefit)	$	4.4		$	(169.7)		$	(5.3)
Effective tax rate	1.1		%	(49.2)		%	(1.9)		%

The difference between the tax provision (benefit) at the statutory federal income tax rate and the tax provision (benefit) as a percentage of income before taxes ("effective tax rate") was as follows:


Fiscal Years	2020		2019		2018

Statutory federal income tax rate	21.0	%	21.0	%	21.0	%
Increase (reduction) in tax rate resulting from:
Foreign income taxed at different rates	1.7	%	(7.3)	%	(6.7)	%
Change in valuation allowance	2.0	%	—	%	—	%
U.S. State income taxes	0.5	%	1.5	%	1.0	%
Stock-based compensation	1.5	%	1.2	%	1.1	%
Excess tax benefit related to stock-based compensation	(1.5)	%	(2.4)	%	(3.2)	%
Effect of U.S. tax law change	—	%	—	%	(7.6)	%
Other U.S. taxes on foreign operations	(1.0)	%	1.3	%	1.6	%
U.S. Federal research and development credits	(2.3)	%	(2.8)	%	(3.7)	%
Tax reserve releases	(4.8)	%	(4.9)	%	(8.7)	%
Intellectual property restructuring and tax law changes	(16.2)	%	(59.8)	%	—	%
Other	0.2	%	3.0	%	3.3	%
Effective tax rate	1.1	%	(49.2)	%	(1.9)	%

The Coronavirus Aid, Relief, and Economic Security Act ("CARES Act"), enacted on March 27, 2020, provides tax relief to individuals and businesses in light of the impacts of COVID-19. It did not result in material adjustments to our income tax provision or to our net deferred tax assets as of the end of the fourth quarter of fiscal 2020.

In December 2020, due to a change in the Netherlands tax law, the statutory tax rate was increased from 21.7% to 25.0%, effective January 1, 2021. As a result, we recorded a one-time tax benefit of $64.0 million due to the revaluation of the Netherlands deferred tax assets.

In December 2019, to align with our international business operations, we completed a non-U.S. intercompany transfer of our intellectual property to a subsidiary in the Netherlands. The transaction resulted in deferred tax assets in the Netherlands and GILTI deferred tax liabilities in the U.S., recorded at the applicable statutory tax rates, resulting in a one-time income tax benefit of approximately $206.3 million in the fourth quarter of fiscal 2019.

Deferred income taxes reflect the net effects of temporary differences between the carrying amounts of assets and liabilities for financial reporting purposes and the amounts used for income tax purposes. The significant components of deferred tax assets and liabilities were as follows:


At the End of Fiscal Year	2020		2019
(In millions)
Deferred tax liabilities:
Global intangible low-taxed income	$	219.7	$	233.7
Purchased intangibles	138.1		158.7

Operating lease right-of-use assets	32.3		35.3
Other	11.3		12.8
Total deferred tax liabilities	401.4		440.5

Deferred tax assets:
Depreciation and amortization	497.1		471.5
Operating lease liabilities	35.0		36.0
U.S. tax credit carryforwards	32.8		34.2
Expenses not currently deductible	32.3		28.0
Foreign net operating loss carryforwards	16.8		16.2
Stock-based compensation	10.6		13.3
U.S. net operating loss carryforwards	7.4		9.8
Other	20.6		14.1
Total deferred tax assets	652.6		623.1
Valuation allowance	(41.3)		(25.3)
Total deferred tax assets	611.3		597.8
Total net deferred tax assets	$	209.9	$	157.3

Reported as:
Non-current deferred income tax assets	$	510.2	$	475.5
Non-current deferred income tax liabilities	(300.3)		(318.2)
Net deferred tax assets	$	209.9	$	157.3

At the end of fiscal 2020, we have U.S. federal and foreign net operating loss carryforwards, or NOLs, of approximately $16.7 million and $83.4 million, respectively. The U.S. federal NOLs will begin to expire in 2026. There is generally no expiration for the foreign NOLs. Utilization of our U.S. federal and state NOLs is subject to annual limitations in accordance with the applicable tax code. We have determined that it is more likely than not that we will not realize a portion of the foreign NOLs and, accordingly, a valuation allowance has been established for such amount.

We have U.S. federal and California research and development credit carryforwards of approximately $11.8 million and $33.1 million, respectively. The U.S. federal tax credit carryforwards will expire beginning 2040. The California research tax credits

have an indefinite carryforward period. We believe that it is more likely than not that we will not realize a significant portion of the California research and development credit carryforwards and, accordingly, a valuation allowance has been established for such amount.

As a result of the Tax Act, we can repatriate foreign earnings back to the U.S. when needed with minimal U.S. income tax consequences, other than the transition tax and GILTI tax. We reinvested a large portion of our undistributed foreign earnings in acquisitions and other investments and intend to bring back a portion of foreign cash that was subject to the transition tax and GILTI. During fiscal 2020, we repatriated $272.7 million of our foreign earnings to the U.S.


Fiscal Years	2020		2019		2018
(In millions)
Beginning balance	$	71.6	$	69.1	$	82.4
Increase related to current year tax positions	8.0		12.6		10.0
(Decrease) increase related to prior years' tax positions	(0.4)		3.8		4.5
Settlement with taxing authorities	(0.5)		(5.7)		(8.9)
Lapse of statute of limitations	(14.6)		(8.2)		(18.9)
Ending balance	$	64.1	$	71.6	$	69.1

We and our subsidiaries are subject to U.S. federal, state, and foreign income taxes. Our tax years are substantially closed for all U.S. federal and state income taxes for audit purposes through 2014. Non-U.S. income tax matters have been concluded for years through 2007. We are currently in various stages of multiple year examinations state, and foreign (multiple jurisdictions) taxing authorities. While we generally believe it is more likely than not that our tax positions will be sustained, it is reasonably possible that future obligations related to these matters could arise. We believe that our reserves are adequate to cover any potential assessments that may result from the examinations and negotiations.

Although timing of the resolution and/or closure of audits is not certain, we do not believe that our gross unrecognized tax benefits would materially change in the next twelve months.

Our practice is to recognize interest and/or penalties related to income tax matters in income tax expense. Our liability for unrecognized tax benefits including interest and penalties was recorded in Other non-current liabilities on our Consolidated Balance Sheets. At the end of fiscal 2020 and 2019, we accrued $9.6 million and $11.5 million, respectively, for interest and penalties.