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Income Taxes
9 Months Ended
Jun. 30, 2018
Income Tax Disclosure [Abstract]  
Income Taxes

9. Income Taxes

The Company recorded an income tax provision of $3.3 million for the three months ended June 30, 2018 and an income tax benefit of $37.7 million for the nine months ended June 30, 2018. The tax provision for the three months ended June 30, 2018 was primarily driven by the income generated during the quarter. The income tax benefit for the nine months ended June 30, 2018 was primarily driven by a discrete benefit of $45.6 million due to the reversal of a valuation allowance against U.S. net deferred tax assets. The tax benefit for the nine months ended June 30, 2018 also included $0.7 million of tax benefits related to the re-measurement of net U.S. deferred tax liabilities to account for the reduced 21% statutory federal income tax rate. The benefit for the nine months ended June 30, 2018 was partially offset by the tax provisions related to foreign income. 

The Company recorded an income tax provision of $3.7 million and $9.9 million, respectively, for the three and nine months ended June 30, 2017. The provision recorded during each period was primarily driven by foreign income. Tax provision during the nine months ended June 30, 2017 was partially offset by $0.9 million of tax benefits related to the reduction of reserves for unrecognized tax benefits resulting from the expiration of statutes of limitations.

The Company evaluates the realizability of its deferred tax assets by tax-paying component and assesses the need for a valuation allowance on a quarterly basis, considering the weight of both positive and negative evidence in making the assessment. The Company evaluates the profitability of each tax-paying component on a historic cumulative basis and forward looking basis, considering tax-planning strategies and the length of credit and loss carryforward and carryback periods, among other factors, in the course of performing this analysis.  As of June 30, 2018, the Company maintained its assertion that it is more likely than not that a substantial portion of U.S. deferred tax assets will be realized, with the exception of certain state tax carryforwards.    

During the first quarter of fiscal year 2018, the Company adopted ASU 2016-09, Compensation-Stock Compensation (Topic 718): Improvements to Employee Share-Based Payment Accounting (“ASU 2016-09). Upon adoption of ASU 2016-09, the Company amended the accounting for employee share-based payment transactions to recognize tax effects resulting from the settlement of stock-based awards as income tax expense or benefit in the income statement in the reporting period in which they occur. Adoption of this ASU required recognition of a cumulative effect adjustment to retained earnings in connection with the establishment of a deferred tax asset for any prior year net excess tax benefits or tax deficiencies not previously recorded. This adjustment resulted in a $4.0 million increase to retained earnings and deferred tax asset for net prior year excess tax benefits, with a corresponding decrease to retained earnings for the establishment of valuation allowance against the deferred tax asset. This increase to the valuation allowance was subsequently part of the valuation allowance reversal during the second quarter of fiscal year 2018.

During the first quarter of fiscal year 2018, the Tax Cuts and Jobs Act (“Tax Reform”) was enacted in the U.S., making significant tax law changes affecting the Company. The SEC issued Staff Accounting Bulletin 118 (“SAB 118”), which provided guidance for companies that had not completed the accounting for the income tax effects of Tax Reform.  Under SAB 118, a company may report provisional amounts based on reasonable estimates where the accounting is incomplete. These amounts are subject to adjustments during a measurement period of up to one year beginning in the reporting period of the enactment date.

Upon the enactment of Tax Reform, the Company was subject to a toll charge in the U.S. on its previously untaxed accumulated foreign earnings.  The toll charge was treated as an inclusion of the Company’s accumulated foreign earnings in U.S. taxable income during the tax year ended September 30, 2018. Any taxes due associated with the toll charge will be payable over an eight year period. The Company has estimated that its accumulated foreign earnings are $120.0 million which is a provisional amount subject to the measurement period described in Staff Accounting Bulletin 118. There are still incomplete components related to the accumulated foreign earnings calculations for older tax years that require additional time to complete the calculations. The Company also has a history of foreign mergers and acquisitions and proper determination of the impact on the accumulated earnings is complex. The Company has estimated a $5.2 million toll charge associated with the taxable foreign earnings, net of foreign tax credits associated with the earnings subject to the toll tax. The Company did not record any provision for currently estimated tax associated with the toll charge as sufficient previously un-benefited tax attributes with valuation allowances existed to offset the resulting tax during the quarter of enactment of the tax law, however, the toll charge reduced the impact of the valuation allowance reversal.  

As a result of Tax Reform, the Company calculated its U.S. tax provision for the three and nine months ended  June 30, 2018 using a blended U.S. statutory tax rate of 24.5% which is a prorated allocation of the 35% rate in effect prior to Tax Reform through December 31, 2017 and the 21% rate in effect for the remainder of the fiscal year. The Company recorded a discrete benefit of $0.7 million in the nine months ended June 30, 2018 due to the impact of the U.S. rate change on its net U.S. deferred tax liabilities.

As of June 30, 2018, the Company maintains its indefinite reinvestment assertion on foreign earnings. The Company is continuing to evaluate the impact of Tax Reform on its reinvestment plans, as the accounting for Tax Reform is completed during the measurement period described in SAB 118.  While the toll charge is a forced deemed repatriation of foreign earnings and an inclusion in U.S. federal taxable income, there are still additional costs of repatriating the foreign earnings such as foreign withholding taxes and state taxes. 

The Company is subject to U.S. federal income tax and various state, local and international income taxes in various jurisdictions. The amount of income taxes paid is subject to the Company’s interpretation of applicable tax laws in the jurisdictions in which it files tax returns. In the normal course of business, the Company is subject to income tax audits in various global jurisdictions in which it operates. The years subject to examination vary for the U.S. and international jurisdictions, with the earliest tax year being 2011. Based on the outcome of these examinations or the expiration of statutes of limitations for specific jurisdictions, it is reasonably possible that the related unrecognized tax benefits could change from those recorded in the Company’s unaudited Consolidated Balance Sheets. The Company currently anticipates that it is reasonably possible that the unrecognized tax benefits will be reduced by approximately $0.2 million within the next twelve months.