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Note 11 - Income Taxes
9 Months Ended
Mar. 31, 2020
Notes to Financial Statements  
Income Tax Disclosure [Text Block]
Note
1
1
:   Income Taxes
 
The Company is subject to U.S. federal income tax and various state, local, and foreign income taxes in numerous jurisdictions. The Company’s domestic and foreign tax liabilities are subject to the allocation of revenues and expenses in different jurisdictions and the timing of recognizing revenues and expenses. Additionally, the amount of income taxes paid is subject to the Company’s interpretation of applicable tax laws in the jurisdictions in which it files.
 
The Company provides for income taxes on an interim basis based on an estimate of the effective tax rate for the year. This estimate is reassessed on a quarterly basis. Discrete tax items are accounted for in the quarterly period in which they occur.
 
On
December 22, 2017,
the Tax Cuts and Jobs Act was enacted in the United States. The Act reduces the U.S. federal corporate tax rate from a graduated rate of
35%
to a flat rate of
21%,
requires companies to pay a
one
-time transition tax on earnings of certain foreign subsidiaries that were previously tax deferred and creates new taxes on certain foreign sourced earnings. Other impacts of tax reform that became effective for the Company beginning in fiscal
2019
include the provisions related to Global Intangible Low Taxed Income (“GILTI”), Foreign Derived Intangible Income (“FDII”), Base Erosion Anti Abuse Tax (“BEAT”), and limitation on tax deductibility of interest expenses.
 
The GILTI provisions are expected to have the most significant impact to the Company. Under the new law, U.S. taxes are imposed on foreign income in excess of a deemed return on tangible assets of its foreign subsidiaries. In general, this foreign income will effectively be taxed at an additional
10.5%
tax rate reduced by any available current year foreign tax credits. The ability to benefit foreign tax credits
may
be limited under the GILTI rules as a result of the utilization of net operating losses, foreign sourced income and other potential limitations within the foreign tax credit calculation.
 
The tax expense for the
third
quarter of fiscal
2020
was a benefit of (
$0.3
) million on a profit before tax of
$0.3
million (an effective tax rate of (
100%
)). The tax expense for the
third
quarter of fiscal
2019
was
$1.0
million on a profit before tax of
$3.0
million (an effective tax rate of
33%
). The tax rate for fiscal
2020
was lower than the U.S. statutory tax rate of
21%
primarily due to the Global Intangible Low Taxed Income (“GILTI”) provisions, the jurisdictional mix of earnings, particularly Brazil with a statutory rate of
34%,
and the impact of permanent deductible and nondeductible items and research credits. The impact of these items on the tax rate is substantial based on the Company’s profit being
$0.3
million in the
third
quarter of
2020.
The tax rate for fiscal
2019
was higher than the U.S. statutory tax rate of
21%
primarily due to the Global Intangible Low Taxed Income (“GILTI”) provisions, which became effective in fiscal
2019,
and the jurisdictional mix of earnings, particularly Brazil with a statutory rate of
34%.
 
For the
first
nine
months of fiscal
2020,
tax expense was
$0.8
million on profit before tax of
$3.4
million (an effective tax rate of
23.5%
). For the
first
nine
months of fiscal
2019,
tax expense was
$2.4
million on profit before tax of
$7.0
million (an effective tax rate of
34%
). The tax rate for fiscal
2020
was higher than the U.S. statutory tax rate of
21%
primarily due to the Global Intangible Low Taxed Income (“GILTI”) provisions, the jurisdictional mix of earnings, particularly Brazil with a statutory rate of
34%,
and the impact of permanent deductible and nondeductible items and research credits. The tax rate for fiscal
2019
was higher than the U.S. statutory tax rate of
21%
primarily due to the Global Intangible Low Taxed Income (“GILTI”) provisions, which became effective in fiscal
2019,
and the jurisdictional mix of earnings, particularly Brazil with a statutory rate of
34%.
 
U.S. Federal tax returns for years prior to fiscal
2016
are generally
no
longer subject to review by tax authorities; however, tax loss carryforwards from earlier years are still subject to adjustment. As of
March 31, 2020,
the Company has substantially resolved all open income tax audits and there were
no
other local or federal income tax audits in progress. In international jurisdictions including Australia, Brazil, Canada, China, Germany, Mexico, New Zealand, Singapore and the UK, which comprise a significant portion of the Company’s operations, the years that
may
be examined vary by country. The Company’s most significant foreign subsidiary in Brazil is subject to audit for the calendar years
2013
– present. During the next
twelve
months, it is possible there will be a reduction of
$0.1
million in long-term tax obligations due to the expiration of the statute of limitations on prior year tax returns.
 
Accounting for income taxes requires estimates of future benefits and tax liabilities. Due to the temporary differences in the timing of recognition of items included in income for accounting and tax purposes, deferred tax assets or liabilities are recorded to reflect the impact arising from these differences on future tax payments. With respect to recorded tax assets, the Company assesses the likelihood that the asset will be realized by addressing the positive and negative evidence to determine whether realization is more likely than
not
to occur. If realization is in doubt because of uncertainty regarding future profitability, the Company provides a valuation allowance related to the asset to the extent that it is more likely than
not
that the deferred tax asset will
not
be realized. Should any significant changes in the tax law or the estimate of the necessary valuation allowance occur, the Company would record the impact of the change, which could have a material effect on the Company’s financial position.
 
No
valuation allowance has been recorded for the Company’s U.S. federal and foreign deferred tax assets related to temporary differences included in taxable income. While the Company continues to believe that forecasted future taxable income and certain available tax planning strategies provide sufficient evidence to, more likely than
not,
support the realization of the tax benefits provided by those differences; the impact of COVID-
19
may
significantly impact our ability to forecast future pre-tax earnings in certain jurisdictions.  If our forecasts are significantly impacted, the Company
may
need to record a valuation allowance on some or all its deferred tax assets as soon as the current fiscal year end.
 
In the U.S., a partial valuation allowance has been provided for foreign tax credit carryforwards due to the uncertainty of generating sufficient foreign source income to utilize those credits in the future and certain state net operating loss carryforwards that will expire in the near future unutilized.