Note 10 - Income Taxes |
6 Months Ended |
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Dec. 31, 2017 | |
Notes to Financial Statements | |
Income Tax Disclosure [Text Block] |
Note 10. Income Taxes:The Company’s effective income tax rate was (
124.7 ) % and 50.8% for the second quarter of fiscal 2018 and fiscal 2017, respectively and (44.8 ) % and 38.8% for the first six months of fiscal 2018 and fiscal 2017, respectively. The changes in the company’s tax rate for the second quarter and first six months of fiscal 2018 compared to second quarter and first six months of fiscal 2017 are due primarily to recording the items attributable to the new tax legislation in the U.S. as described below. Also included in the 2018 effective tax rate is discrete tax benefit of
$0.3 million and $0.7 million for the second quarter and first six months of fiscal year 2018 for the tax benefit of stock option exercises offset by a net discrete tax expense of $2.9 million and $3.8 million for the second quarter and first six months of fiscal 2018 related to the revaluation of contingent consideration, which is not tax deductible. Discrete tax expense for the second quarter and first six months of fiscal 2017 included $4.6 million of expense related to the revaluation of contingent consideration.On December 22, 2017, the U.S. government enacted comprehensive tax legislation commonly referred to as the Tax Cuts and Jobs Act (the “Tax Act”). The Tax Act makes broad and complex changes to the U.S. tax code which will impact our fiscal year ended June30, 2018 including, but not limited to (1 ) reducing the U.S. federal corporate tax rate, (2 ) requiring a one -time transition tax on certain unrepatriated earnings of foreign subsidiaries that may electively be paid over eight years, and (3 ) accelerated first year expensing of certain capital expenditures. The Tax Act reduces the federal corporate tax rate from 35 percent to 21 percent effective January 1, 2018. Internal Revenue Code Section 15 provides that our fiscal year ended June 30, 2018. We calculated a blended corporate tax rate of 28.1 percent for fiscal year 2018, which is based on a proration of the applicable tax rates before and after effective date of the Tax Act. The statutory tax rate of 21 percent will apply for fiscal 2019 and beyond.The Tax Act also puts in place new tax laws that will impact our taxable income beginning in fiscal 2019, which include, but are not limited to (1 ) creating a Base Erosion Anti-abuse Tax (BEAT), which is a new minimum tax, (2 ) generally eliminating U.S. federal income taxes on dividends from foreign subsidiaries, (3 ) a new provision designed to tax currently global intangible low-taxed income (GILTI), which allows for the possibility of utilizing foreign tax credits and a deduction equal to50 percent to offset the income tax liability (subject to some limitations), (4 ) a provision that could limit the amount of deductible interest expense, (5 ) the repeal of the domestic production activity deduction, (6 ) limitations on the deductibility of certain executive compensation, and (7 ) limitations on the utilization of foreign tax credits to reduce the U.S. income tax liability.Shortly after the Tax Act was enacted, the SEC staff issued Staff Accounting Bulletin No. 118, Income Tax Accounting Implications of the Tax Cuts and Jobs Act (SAB 118 ) which provides guidance on accounting for the Tax Act’s impact. SAB
118 provides a measurement period, which in no case should extend beyond one year from the Tax Act enactment date, during which a company acting in good faith may complete the accounting for the impacts of the Tax Act under ASC Topic 740. In accordance with SAB 118, the Company must reflect the income tax effects of the Tax Act in the reporting period in which the accounting under ASC Topic 740 is complete.To the extent that a company ’s accounting for certain income tax effects of the Tax Act is incomplete, the Company can determine a reasonable estimate for those effects and record a provisional estimate in the financial statements in the
first reporting period in which a reasonable estimate can be determined. If a Company cannot determine a provisional estimate to be included in the financial statements, the Company should continue to apply ASC 740 based on the provisions of the tax laws that were in effect immediately prior to the Tax Act being enacted. If a Company is unable to provide a reasonable estimate of the impacts of the Tax Act in a reporting period, a provisional amount must be recorded in the first reporting period in which a reasonable estimate can be determined.We have recorded a provisional net tax benefit of
$33.5 million related to the Tax Act in the period ending December 31, 2017. This provisional net benefit primarily consists of a net benefit of $37.0 million due to the remeasurement of our deferred tax accounts to reflect the corporate rate reduction impact to our net deferred tax balances and a net expense for the transition tax of $3.5 million.Reduction in U.S. Corporate Rate: The Act reduces the U.S. federal statutory corporate tax rate to a blended
28.1 percent in fiscal year ending June 30, 2018 and 21 percent for fiscal year ending June 30, 2019 and beyond. While we are able to make a reasonable estimate of the impact of the reduction in corporate rate, we are continuing to analyze the temporary differences that existed on the date of enactment, the temporary differences originating in the current fiscal year prior to December 22, 2017, and the temporary differences we expect will reverse prior to June 30, 2018.
Transition Tax: The tra nsition tax is a tax on the previously untaxed accumulated and current earnings and profits (E&P) of certain of our foreign subsidiaries as of
December 22, 2017. In order to determine the amount of the Transition Tax, we must determine, in addition to other factors, the amount of post-1986 E&P of the relevant subsidiaries, as well as the amount of non-U.S. income taxes paid on such earnings. E&P is similar to retained earnings of the subsidiary, but requires other adjustments to conform to U.S. tax rules. We are able to make a reasonable estimate of the transition tax and recorded a provisional transition tax obligation of $3.5 million which theCompany expects to elect to pay, net of certain tax credit carryforwards, over
eight years beginning in fiscal year 2019. $0.3 million of this liability is recorded as current with the remaining $3.2 million classified as a long-term liability within our December 31, 2017 balance sheet. However, we are awaiting further interpretative guidance including information regarding state income tax implications and continuing to gather additional information to more precisely compute the amount of the transition tax. We expect that our estimate will be finalized in advance of the filing of our June 30, 2018 Form 10 -K.Global intangible low-taxed income (GILTI): The Tax Act includes a provision designed to currently tax global intangible low-taxed income starting in fiscal 2019. Due to the complexity of the new GILTI tax rules, we are continuing to evaluate this provision of the Tax Act, the application of ASC 740, and are considering available accounting policy alternatives to adopt to either record the U.S. income tax effect of future GILTI inclusions in the period in which they arise or establish deferred taxes with respect to the expected future tax liabilities associated with future GILTI inclusions. In addition, we are awaiting further interpretive guidance in connection with the computation of the GILTI tax. For these reasons, we are
not yet able to reasonably estimate the effect of this provision of the Tax Act. As of June 30, 2017, our practice and intention was to reinvest the earnings in our subsidiaries outside of the U.S., and no U.S. deferred income taxes or foreign withholding taxes were recorded. As of December 31, 2017 we continue to assert that we plan to reinvest these earnings. The transition tax noted above will result in the previously untaxed foreign earnings being included in the federal and state fiscal 2018 taxable income. We are currently analyzing our global working capital requirements and the potential tax liabilities that would be incurred if the non-U.S. subsidiaries distribute cash to the U.S. parent, which include local country withholding tax and potential U.S. state taxation. Therefore, we are not yet able to reasonably estimate the effect of this provision of the Tax Act and have not recorded any withholding or state tax liabilities.We are also currently analyzing other provisions of the Tax Act that come into effect for tax years starting
July 1, 2018 to determine if these items would impact the effective tax rate. These provisions include BEAT, eliminating U.S. federal income taxes on dividends from foreign subsidiaries, the new provision that could limit the amount of deductible interest expense, the limitations on the deductibility of certain executive compensation, and state tax implications of this federal tax legislation. |