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Income Taxes
9 Months Ended
Oct. 31, 2013
Income Taxes

6. Income Taxes

Income tax (benefit)/expense for continuing operations of $(3.9) million and $52.1 million were recorded in the three and nine months ended October 31, 2013, respectively, compared to $(1.2) million and $5.6 million for the same periods last year. The Company recorded a discrete period tax (benefit) expense of approximately $(3.3) million and $47.3 million during the three and nine months ended October 31, 2013 that were primarily related to a valuation allowance recorded on the Company’s domestic deferred tax assets during the second quarter, and the recognition of a $4.3 million tax benefit during the third quarter resulting from a change in the Company’s decision to carryback its domestic net operating loss generated in the prior fiscal year. During the nine months ended October 31, 2012, the Company recognized a pretax loss on its investment in Diberil for which no tax benefit was recorded. The effective tax rates for continuing operations for the three and nine months ended October 31, 2013 were 20.2% and (77.2) %, respectively, compared to (16.1) % and 35.3% for the same periods last year. The difference between the current year effective rates and the statutory effective rate resulted from the discrete period tax expense and benefit discussed above, an impairment to goodwill during the second quarter on which no tax benefit was recorded, an increase in the valuation allowance recorded against deferred tax assets generated in the current year in the U.S. and certain foreign jurisdictions, and tax accruals recorded on certain foreign tax contingencies. The difference between the actual effective tax rates and the statutory tax rate in the prior year periods resulted from the loss on the equity investment on which no tax benefit was recorded.

The Company recorded the valuation allowance on its domestic deferred tax asset during the second quarter due to losses from domestic operations and forecasts of losses for the current year to the extent we expected to be in a cumulative loss position for the three year period ending January 31, 2014. Based on this assessment, the Company could not support the realization of its domestic deferred tax assets in future periods, and the remaining domestic deferred tax asset was written off. The Company does maintain $2.3 million of deferred tax assets in various foreign jurisdictions as of October 31, 2013, where management believes that realization is more likely than not. Management will continue to evaluate all of the evidence in future quarters and will make a determination as to whether it is more likely than not that deferred tax assets will be realized in future periods. The establishment of a valuation allowance does not have any impact on cash, nor does such an allowance preclude the Company from using its loss carryforwards or utilizing other deferred tax assets in the future.

The Company recorded $3.6 million of tax expense on unrecognized tax benefits for certain foreign tax contingencies during the nine months ended October 31, 2013, as compared to $0.2 million for the same period last year. As of October 31, 2013 and January 31, 2013, the total number of unrecognized tax benefits recorded was $16.0 million and $13.4 million respectively, of which substantially all would affect the effective tax rate if recognized. It is reasonably possible that the amount of unrecognized tax benefits will decrease during the next year by approximately $6.8 million due to settlements of audit issues and expiration of statutes of limitation. The Company classifies uncertain tax positions as non-current income tax liabilities unless expected to be paid in one year. The Company reports income tax-related interest and penalties as a component of income tax expense. As of October 31, 2013 and January 31, 2013, the total amount of liability for income tax-related interest and penalties was $9.5 million and $8.8 million, respectively.