Income Taxes

Domestic and foreign components of income (loss) before income taxes were as follows:



	Year Ended
	September 27, 2014		September 28, 2013		September 29, 2012
	(In thousands)
Domestic	$	92,961	$	3,517	$	(7,548	)
Foreign	68,778		99,889		57,491
Total	$	161,739	$	103,406	$	49,943

The provision for (benefit from) income taxes consists of the following:



	Year Ended
	September 27, 2014			September 28, 2013			September 29, 2012
	(In thousands)
Federal:
Current	$	5,889		$	—		$	(3,223	)
Deferred	(43,789		)	(6,611		)	(154,292		)
State:
Current	(100		)	1,388			(124		)
Deferred	(1,251		)	(189		)	(4,408		)
Foreign:
Current	27,937			31,249			28,928
Deferred	(24,112		)	(1,782		)	2,828
Total provision for (benefit from) income taxes	$	(35,426	)	$	24,055		$	(130,291	)

The tax effects of temporary differences that give rise to significant portions of deferred tax assets and liabilities are as follows:



	As of
	September 27, 2014			September 28, 2013
	(In thousands)
Deferred tax assets:
U.S. net operating loss carryforwards	$	452,754		$	473,025
Foreign net operating loss carryforwards	298,693			307,404
Acquisition related intangibles	58,442			73,205
Accruals not currently deductible	62,148			50,835
Property, plant and equipment	23,754			20,557
Tax credit carryforwards	9,155			24,330
Reserves not currently deductible	18,612			22,588
Stock compensation expense	14,173			13,970
Unrealized losses	4,417			4,437
Other	745			132
Valuation allowance	(663,193		)	(788,260		)
Total deferred tax assets	279,700			202,223
Deferred tax liabilities on foreign earnings	(19,872		)	(19,873		)
Other deferred tax liabilities	(9,521		)	(1,195		)
Net deferred tax assets	$	250,307		$	181,155
Recorded as:
Current deferred tax assets	$	37,738		$	23,276
Non-current deferred tax assets	217,645			157,879
Non-current deferred tax liabilities	(5,076		)	—
Net deferred tax assets	$	250,307		$	181,155

The Company offsets current deferred tax assets and liabilities and non-current deferred tax assets and liabilities by tax-paying jurisdiction. The resulting net amounts by tax jurisdiction are then aggregated without further offset.

A valuation allowance is established or maintained when, based on currently available information and other factors, it is more likely than not that all or a portion of the deferred tax assets will not be realized. The Company regularly assesses its valuation allowance against deferred tax assets on a jurisdiction by jurisdiction basis. The Company considers all available positive and negative evidence, including future reversals of temporary differences, projected future taxable income, tax planning strategies and recent financial results.

Prior to 2012, based on historical evidence (primarily cumulative losses), the Company had a full valuation allowance against its net deferred tax assets in the U.S. and certain foreign jurisdictions. In 2012, the Company recorded a partial release of its U.S. valuation allowances in recognition of its recent history of cumulative profits and continued projected earnings.

During the fourth quarters of 2014 and 2013, the Company concluded that it was more likely than not that it would be able to realize the benefit of an additional portion of its deferred tax assets in the U.S. and certain foreign jurisdictions. The Company based this conclusion on a continued pattern of recent income before tax, certain global restructuring actions and a significant increase in projected future operating income in the U.S. and certain other foreign jurisdictions. As a result, the Company released $87.6 million and $21.5 million of the valuation allowance attributable to certain U.S. and foreign deferred tax assets and net operating losses during 2014 and 2013, respectively.

To the extent the Company continues to consistently earn, as well as reliably project, income in the appropriate jurisdictions, it is reasonably possible that the valuation allowance will be further reduced at such time when such positive evidence can be substantiated. An additional year of strong and predictable earnings may be sufficient to warrant an additional release of the valuation allowance in 2015, although such positive evidence would need to be weighed against any negative evidence existing at that time.

As of September 27, 2014, U.S. income taxes have not been provided for approximately $543.6 million of cumulative undistributed earnings of several non-U.S. subsidiaries. The Company intends to reinvest these earnings indefinitely in operations outside of the U.S. Determination of the amount of unrecognized deferred tax liabilities on these undistributed earnings is not practicable.

As of September 27, 2014, the Company has cumulative net operating loss carryforwards for federal, state and foreign tax purposes of $1,207.2 million, $888.9 million and $1,076.8 million, respectively. The federal and state net operating loss carryforwards begin expiring in 2023 and 2015, respectively, and expire at various dates through 2033. Certain foreign net operating losses start expiring in 2015. However, the majority of foreign net operating losses carryforward indefinitely. The Tax Reform Act of 1986 and similar state provisions impose restrictions on the utilization of net operating loss and tax credit carryforwards in the event of an “ownership change” as defined in the Internal Revenue Code. As of September 27, 2014, the Company had $6.8 million of federal net operating losses subject to an annual limitation and may utilize approximately $1.7 million of these net operating losses each year. Additionally, the utilization of certain foreign net operating losses may be restricted due to changes in ownership and business operations.

The Company has been granted tax holidays for certain of its subsidiaries in India, Singapore, Thailand and China. Tax benefits arising from these tax holidays were $0.7 million for 2014 ($0.01 per diluted shares), $1.5 million for 2013 ($0.02 per diluted share) and $3.1 million for 2012 ($0.04 per diluted share). The Company's tax holiday in Singapore expired in 2012 and tax holidays in Thailand and China expired in 2013. The Company's tax holiday in India expires in 2019, excluding potential renewals, and is subject to certain conditions with which the Company expects to comply.

Following is a reconciliation of the statutory federal tax rate to the Company's effective tax rate:



	Year Ended
	September 27, 2014		September 28, 2013		September 29, 2012
Federal tax at statutory rate	35.00	%	35.00	%	35.00	%
Effect of foreign operations	(4.34	)	(8.17	)	21.73
Foreign income inclusion	1.17		4.08		10.48
Change in valuation allowance	(4.23	)	11.54		(6.74	)
Permanent items	2.69		0.26		3.11
Change to other comprehensive income	2.05		—		(6.64	)
Release of valuation allowance	(54.18	)	(20.79	)	(317.76	)
State income taxes, net of federal benefit	(0.06	)	1.34		(0.06	)
Effective tax rate	(21.90	)%	23.26	%	(260.88	)%

A reconciliation of the beginning and ending amount of total unrecognized tax benefits, excluding accrued penalties and interest, is as follows:



	Year Ended
	September 27, 2014			September 28, 2013
	(In thousands)
Balance, beginning of year	$	65,148		$	54,224
Increase related to prior year tax positions	—			13,238
Decrease related to prior year tax positions	(11,274		)	(5,672		)
Increase related to current year tax positions	4,993			3,358
Settlement	(4,630		)	—
Balance, end of year	$	54,237		$	65,148

As of September 27, 2014, the Company had reserves of $31.9 million for the payment of interest and penalties relating to unrecognized tax benefits. The Company accrued interest and penalties related to unrecognized tax benefits of $5.6 million in 2014, $1.9 million in 2013, and $5.6 million in 2012. The Company recognizes interest and penalties related to unrecognized tax benefits as a component of income tax expense.

The Company conducts business globally and, as a result, files income tax returns in the United States federal jurisdiction and various state and foreign jurisdictions. In the normal course of business, the Company is subject to examination by taxing authorities throughout the world. The Company is currently being audited by the Internal Revenue Service for tax years 2008 through 2010. To the extent the final tax liabilities are different from the amounts accrued, this would result in an increase or decrease in net operating losses and would not have an impact on the consolidated financial statements. Additionally, the Company is being audited by various state tax agencies and certain foreign countries. To the extent the final tax liabilities are different from the amounts accrued, the increases or decreases would be recorded as income tax expense or benefit in the consolidated statements of income. Although the Company believes that the resolution of these audits will not have a material adverse impact on the Company’s results of operations, the outcome is subject to uncertainty.

In general, the Company is no longer subject to United States federal or state income tax examinations for years before 2003, and to foreign examinations for years prior to 2003 in its major foreign jurisdictions. Although the timing of the resolution of audits is highly uncertain, it is reasonably possible that the balance of gross unrecognized tax benefits could significantly change in the next 12 months. However, given the number of years subject to audit and the number of matters being examined, the Company is unable to estimate the full range of possible adjustments to the balance of gross unrecognized tax benefits.