Income Taxes

9 Months Ended

Oct. 27, 2019

The Company’s effective tax rate differs from the statutory federal income tax rate of 21% primarily due to the regional mix of income and a true up related to the impact of finalized regulations on the mandatory deemed repatriation of foreign earnings ("U.S. Transition Tax").

The Company uses a two-step approach to recognize and measure uncertain tax positions ("UTP"). The first step is to evaluate the tax position for recognition by determining if the weight of available evidence indicates that it is more likely than not that the position will be sustained on audit, including resolution of related appeals or litigation processes, if any. The second step is to measure the tax benefit as the largest amount that is more than 50% likely of being realized upon ultimate settlement.

A reconciliation of the beginning and ending amount of gross unrecognized tax benefits (before the federal impact of state items) is as follows:



(in thousands)
Balance at January 27, 2019	$	18,293
Additions based on tax positions related to the current fiscal year	258
Additions based on tax positions related to prior years	6,468
Reductions for settlements with tax authorities	(1,530		)
Balance at October 27, 2019	$	23,489

Included in the balance of gross unrecognized tax benefits at October 27, 2019 and January 27, 2019 are $9.6 million and $4.5 million, respectively, of net tax benefits (after the federal impact of state items), that, if recognized, would impact the effective tax rate, prior to consideration of any required valuation allowance.

The liability for UTP is reflected in the Balance Sheets as follows:



(in thousands)	October 27, 2019		January 27, 2019
Deferred tax assets - non-current	$	12,608	$	12,492
Other long-term liabilities	9,550		4,479
Total accrued taxes	$	22,158	$	16,971

The Company’s policy is to include net interest and penalties related to unrecognized tax benefits in the "Provision for taxes" in the Statements of Income.

Tax years prior to 2013 (the Company’s fiscal year 2014) are generally not subject to examination by the U.S. Internal Revenue Service ("IRS") except for items involving tax attributes that have been carried forward to tax years whose statute of limitations remains open. For state returns, the Company is generally not subject to income tax examinations for calendar years prior to 2012 (the Company’s fiscal year 2013). The Company has a significant tax presence in Switzerland for which Swiss tax filings have been examined through fiscal year 2018. The Company is also subject to routine examinations by various foreign tax jurisdictions in which it operates. The Company believes that adequate provisions have been made for any adjustments that may result from tax examinations. However, the outcome of tax audits cannot be predicted with certainty. If any issues addressed in the Company’s tax audits are resolved in a manner not consistent with the Company's expectations, the Company could be required to adjust its provision for income taxes in the period such resolution occurs.

The Company’s regional income (loss) from continuing operations before taxes and equity in net (gains) losses of equity method investments was as follows:



	Three Months Ended					Nine Months Ended
(in thousands)	October 27, 2019		October 28, 2018			October 27, 2019			October 28, 2018
Domestic	$	2,212	$	(1,647	)	$	(12,682	)	$	(12,871	)
Foreign	18,414		12,341			58,865			49,746
Total	$	20,626	$	10,694		$	46,183		$	36,875