Quarterly report pursuant to Section 13 or 15(d)

Note 11 - Income Taxes

v3.10.0.1
Note 11 - Income Taxes
6 Months Ended
Dec. 31, 2018
Notes to Financial Statements  
Income Tax Disclosure [Text Block]
Note
1
1
. Income Taxes:
 
The Company’s effective income tax rate for the
second
quarter of fiscal
2019
and
2018
was
19.3%
 and (
124.8
)% of consolidated earnings before income taxes, and (
11.2
)% and (
44.8
)% for the
first
six
months of fiscal
2019
and
2018,
respectively. The change in the Company’s tax rate for the
second
quarter and
first
six
months of fiscal
2019
 compared to
second
quarter and
first
six
months of fiscal
2018
was driven by discrete tax items.
 
The Company recognized total net benefits related to discrete tax items of
$1.1
 million during the
second
quarter and
$5.3
 million during the
first
six
months of fiscal
2019.
 U.S. tax reform (as described further below) resulted in
$0.6
 million tax benefit for the
second
quarter and
first
six
months of fiscal
2019.
  Share-based compensation excess tax benefit contributed
$0.3
million and
$3.7
million in the
second
quarter and
first
six
months of
2019,
respectively.
 
The Company recognized total net benefits related to discrete tax items of
$31.0
million during the
second
quarter and
$31.5
million during the
first
six
months of fiscal
2018.
 U.S. tax reform (as described further below) resulted in
$33.5
million tax benefit for the
second
quarter and
first
six
months of fiscal
2018.
  This tax benefit was partially 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.
 
On
December 22, 2017,
the Tax Cuts and Jobs Act (the “Tax Act”) was enacted, which reduced the U.S. federal corporate tax rate from
35%
to
21%,
required companies to pay a
one
-time transition tax on earnings of certain foreign subsidiaries that were previously tax deferred and created new taxes on certain foreign sourced earnings. The Tax Act added many new provisions including changes the deduction for executive compensation, a tax on global intangible low taxed income (“GILTI”), the base erosion anti abuse tax (“BEAT”) and a deduction for foreign derived intangible income (“FDII”). The SEC staff issued Staff A
ccounting Bulletin (“SAB
118”
) later codified as ASU
2018
-
05
Amendments to SEC Paragraphs Pursuant to SEC Staff Accounting Bulletin (SAB)
No.
118
, which provides a measurement period of up to
one
year from the Tax Act’s enactment date to complete the accounting for the effects of the Tax Act.
 
During the quarter, the Company recorded a net discrete benefit of
$0.6
million related to the mandatory deemed repatriation tax calculation which is inclusive of a benefit for a dividends received deduction for certain foreign tax credits offset by an increased expense due to the Company’s refinement of the calculation as the tax return is being prepared as well as increased expense due to interpretation of guidance issued within the quarter.  The additional dividends received deduction is based on our assessment of the treatment under the applicable provisions of the Tax Act as currently written and enacted. If, in the future, Congress or the Department of the Treasury provides legislative or regulatory updates, this could change our assessment of the benefit associated with the dividends received deduction, and we
may
be required to recognize additional tax expense up to the full amount of the
$4.3
 million in the period such updates are issued.
 
Measurement period adjustments recorded during the
second
quarter and
first
six
months of fiscal
2019
related to the mandatory repatriation inclusion and were approximately
$
2.1
million, all of which had an impact on the effective rate. The Company is at the end of the measurement period allowed under ASU
2018
-
05,
 but anticipates additional interpretations and clarifications to be issued by the U.S. Treasury Department, which
may
affect future period tax estimates.
The Company made the accounting policy election to treat taxes due on U.S. inclusions in taxable income related to GILTI as a current period expense when incurred.