Income Taxes

9 Months Ended

Mar. 28, 2020

Income Tax Disclosure [Abstract]

Income Taxes

Note 14. Income Taxes

The Company recorded an income tax provision of $38.8 million and $57.0 million for the three and nine months ended March 28, 2020, respectively. The Company recorded an income tax provision of $5.6 million and $22.2 million for the three and nine months ended March 30, 2019, respectively.

The income tax provision for the three and nine months ended March 28, 2020 primarily relates to a $31.6 million charge for withholding taxes expected to be paid on the repatriation of $316.4 million of foreign earnings that the Company no longer considers to be permanently reinvested. In light of the economic uncertainty caused by COVID-19, the Company reevaluated its historic assertion on foreign earnings and no longer considers these earnings to be permanently reinvested. The repatriation of these earnings will increase available cash in the U.S. and provide greater U.S. financial flexibility to assist the Company in navigating the expected downturn in the economy. The foreign earnings can be repatriated to the U.S. without incurring any significant additional U.S current or deferred tax expense. In addition, the income tax provision for the period includes the income tax in certain foreign and state jurisdictions based on the Company’s forecasted pre-tax income or loss for the respective fiscal year. The income tax provision for the three and nine months ended March 30, 2019 primarily relates to income tax in certain foreign and state jurisdictions based on the Company’s forecasted pre-tax income or loss for the respective fiscal year.

The income tax provision recorded differs from the expected tax provision that would be calculated by applying the federal statutory rate to the Company’s income from continuing operations before taxes primarily due to the withholding taxes accrued on foreign earnings and the changes in valuation allowance for deferred tax assets attributable to the Company’s domestic and foreign income (loss) from continuing operations.

On March 27, 2020 the House passed the Coronavirus Aid, Relief, and Economic Security Act (The CARES Act), also known as the Third COVID-19 Supplemental Relief bill, and the president signed the legislation into law. Tax provisions of the Act include the deferral of certain payroll taxes, relief for retaining employees, and other provisions. We do not expect the provisions of the legislation to have a significant impact on the effective tax rate or the income tax payable and deferred income tax positions of the Company. We continue to monitor additional guidance issued by the U.S. Treasury Department, the Internal Revenue Service and others.

As of March 28, 2020, and June 29, 2019, the Company’s unrecognized tax benefits totaled $50.6 million and $50.9 million, respectively, and are included in deferred taxes and other non-current tax liabilities, net. The Company had $3.5 million accrued for the payment of interest and penalties at March 28, 2020. The timing and resolution of income tax examinations is uncertain, and the amounts ultimately paid, if any, upon resolution of issues raised by the taxing authorities may differ from the amounts accrued for each year. Although the Company does not expect that our balance of gross unrecognized tax benefits will change materially in the next 12 months, given the uncertainty in the development of ongoing income tax examinations, the Company is unable to estimate the full range of possible adjustments to this balance.