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Income Taxes
12 Months Ended
Jul. 31, 2019
Income Tax Disclosure [Abstract]  
Income Taxes
9. Income Taxes
The provision for income taxes consisted of the following for the periods indicated:
 
Twelve Months Ended July 31,
(In millions)
2019
 
2018
 
2017
Current:
 
 
 
 
 
Federal
$
271

 
$
197

 
$
345

State
67

 
38

 
36

Foreign
14

 
14

 
8

 Total current
352

 
249

 
389

Deferred:
 
 
 
 
 
Federal
(23
)
 
(14
)
 
12

State
(4
)
 
2

 
2

Foreign
(1
)
 

 
2

Total deferred
(28
)
 
(12
)
 
16

Total provision for income taxes
$
324

 
$
237

 
$
405


Our tax provision for the twelve months ended July 31, 2018 and 2017 have been restated to reflect the full retrospective application of ASU 2014-09, “Revenue from Contracts with Customers (Topic 606).” See Note 1, “Description of Business and Summary of Significant Accounting Policies - Accounting Standards Recently Adopted,” for more information.
We recognized excess tax benefits on share-based compensation of $120 million, $100 million, and $72 million in the provision for income taxes for the twelve months ended July 31, 2019, 2018, and 2017, respectively.
The sources of income before the provision for income taxes consisted of the following for the periods indicated:
 
Twelve Months Ended July 31,
(In millions)
2019
 
2018
 
2017
United States
$
1,826

 
$
1,528

 
$
1,383

Foreign
55

 
38

 
7

Total
$
1,881

 
$
1,566

 
$
1,390


Differences between income taxes calculated using the federal statutory income tax rate and the provision for income taxes were as follows for the periods indicated:
 
Twelve Months Ended July 31,
(In millions)
2019
 
2018
 
2017
Income before income taxes
$
1,881

 
$
1,566

 
$
1,390

 
 
 
 
 
 
U.S. federal statutory rate
21
%
 
26.9
%
 
35
%
 
 
 
 
 
 
Statutory federal income tax
$
395

 
$
420

 
$
486

State income tax, net of federal benefit
50

 
29

 
24

Federal research and experimentation credits
(48
)
 
(38
)
 
(24
)
Domestic production activities deduction

 
(28
)
 
(34
)
Share-based compensation
15

 
11

 
14

Federal excess tax benefits related to share-based compensation
(106
)
 
(94
)
 
(69
)
2017 Tax Act - Deferred tax re-measurement

 
(29
)
 

Capital loss on subsidiary reorganization

 
(35
)
 

Effects of non-U.S. operations
13

 
1

 
6

Other, net
5

 

 
2

Total provision for income taxes
$
324

 
$
237

 
$
405


The Tax Cuts and Jobs Act (2017 Tax Act) was enacted on December 22, 2017 and reduced the U.S. statutory federal corporate tax rate from 35% to 21%. The effective date of the tax rate change was January 1, 2018. The change resulted in a
blended lower U.S. statutory federal rate of 26.9% for fiscal year 2018. In fiscal 2019, we fully benefited from the enacted lower tax rate of 21%.
We recorded a provisional benefit of $29 million for fiscal 2018 related to the re-measurement of certain deferred tax balances as a result of the 2017 Tax Act. In the second quarter of fiscal 2019, we completed our accounting for the income tax effects of the 2017 Tax Act, and there have been no material adjustments during the fiscal 2019 period.
During fiscal year 2018, we completed a reorganization which resulted in a taxable liquidation of a subsidiary. The transaction gave rise to a capital loss which is available for carryback to prior years to offset capital gain income previously recognized. As a result, we recognized a tax benefit of $35 million during the fourth quarter of fiscal 2018.
The state income tax line in the table above includes excess tax benefits related to share-based compensation of $14 million, $6 million and $3 million for the twelve months ended July 31, 2019, 2018 and 2017, respectively.
Significant deferred tax assets and liabilities were as follows at the dates indicated:
 
July 31,
(In millions)
2019
 
2018
Deferred tax assets:
 
 
 
Accruals and reserves not currently deductible
$
13

 
$
12

Deferred rent
8

 
8

Accrued and deferred compensation
48

 
41

Loss and tax credit carryforwards
117

 
97

Share-based compensation
47

 
49

Other, net
3

 
3

Total gross deferred tax assets
236

 
210

   Valuation allowance
(107
)
 
(93
)
       Total deferred tax assets
129

 
117

Deferred tax liabilities:
 
 
 
   Deferred revenue
66

 
91

Intangible assets
71

 
65

Property and equipment
20

 
19

Other, net
8

 
8

Total deferred tax liabilities
165

 
183

Net deferred tax liabilities
$
(36
)
 
$
(66
)

The components of total net deferred tax liabilities, net of valuation allowances, as shown on our consolidated balance sheets were as follows at the dates indicated:
 
July 31,
(In millions)
2019
 
2018
Long-term deferred income taxes included in other assets
$
1

 
$
2

Long-term deferred income tax liabilities
(37
)
 
(68
)
Net deferred tax liabilities
$
(36
)
 
$
(66
)

We have provided a valuation allowance related to state research and experimentation tax credit carryforwards, foreign loss carryforwards, and state operating and capital loss carryforwards that we believe are unlikely to be realized. Changes in the valuation allowance during the twelve months ended July 31, 2019 were primarily related to an increase in the valuation allowance for state research and experimentation tax credit. Changes in valuation allowance during the twelve months ended July 31, 2018 were primarily related to an increase in the valuation allowance for state research and experimentation tax credit and foreign loss carryforwards.
At July 31, 2019, we had total federal net operating loss carryforwards of approximately $42 million that will start to expire in fiscal 2032. Utilization of the net operating losses is subject to annual limitation. The annual limitation may result in the expiration of net operating losses before utilization.
At July 31, 2019, we had total state net operating loss carryforwards of approximately $133 million for which we have recorded a deferred tax asset of $9 million and a valuation allowance of $7 million. The state net operating losses will start to expire in fiscal 2027. Utilization of the net operating losses is subject to annual limitation. The annual limitation may result in the expiration of net operating losses before utilization.
At July 31, 2019, we had Singapore operating loss carryforwards of approximately $62 million and Brazil operating loss carryforwards of approximately $34 million which have an indefinite carryforward period. We maintain a full valuation allowance with respect to operating losses in these jurisdictions, as there is not sufficient evidence of future sources of taxable income required to utilize such carryforwards.
At July 31, 2019, we had California research and experimentation credit carryforwards of approximately $129 million. We recorded a full valuation on the related deferred tax asset, as we believe it is more likely than not that these credits will not be utilized.
Unrecognized Tax Benefits
The aggregate changes in the balance of our gross unrecognized tax benefits were as follows for the periods indicated:
 
Twelve Months Ended July 31,
(In millions)
2019
 
2018
 
2017
Gross unrecognized tax benefits, beginning balance
$
90

 
$
61

 
$
60

Increases related to tax positions from prior fiscal years, including acquisitions
13

 
10

 
8

Decreases related to tax positions from prior fiscal years

 
(3
)
 
(8
)
Increases related to tax positions taken during current fiscal year
23

 
23

 
9

Settlements with tax authorities
(1
)
 
(1
)
 
(8
)
Lapse of statute of limitations
$
(5
)
 
$

 
$

Gross unrecognized tax benefits, ending balance
$
120

 
$
90

 
$
61


The total amount of our unrecognized tax benefits at July 31, 2019 was $120 million. Net of related deferred tax assets, unrecognized tax benefits were $75 million at that date. If we were to recognize these net benefits, our income tax expense would reflect a favorable net impact of $75 million. We do not believe that it is reasonably possible that there will be a significant increase or decrease in unrecognized tax benefits over the next 12 months.
We file U.S. federal, U.S. state, and foreign tax returns. Our major tax jurisdiction is the U.S. federal jurisdiction. For U.S. federal tax returns we are no longer subject to tax examinations for years prior to fiscal 2014.
We recognize interest and penalties related to unrecognized tax benefits within the provision for income taxes. Amounts accrued at July 31, 2019 and July 31, 2018 for the payment of interest and penalties were not significant. The amounts of interest and penalties that we recognized during the twelve months ended July 31, 2019, 2018 and 2017 were also not significant.