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Income Taxes
6 Months Ended
Jun. 28, 2014
Income Taxes [Abstract]  
Income Taxes

7  Income Taxes

 

The Company's effective tax rate was 13.9% and 14.7% for the three months ended June 28, 2014 and June 29, 2013, respectively. The Company's effective tax rate was 14.4% for the six months ended June 28, 2014 and a tax benefit of 1.1% for the six months ended June 29, 2013. The income tax provision for the six months ended June 29, 2013 included a $31 million tax benefit related to the completion of tax audit examinations. In addition, the research and development tax credit (“R&D Tax Credit) was retroactively extended in January 2013 for the 2012 and 2013 tax years. The entire $3 million benefit related to the 2012 tax year was recorded in the first quarter of 2013, and the 2013 benefit was included in the 2013 annual effective tax rate. This R&D Tax Credit expired at the end of 2013 and is not applicable for 2014. The net income tax benefits related to the completed tax audit examinations and the 2012 R&D Tax Credit decreased the Company's effective tax rate by 16.4 percentage points in the six months ended June 29, 2013. The remaining differences between the quarter and year-to-date effective tax rates for 2014 and 2013 were primarily attributable to differences in the proportionate amounts of pre-tax income recognized in jurisdictions with different effective tax rates.

The Company accounts for its uncertain tax return reporting positions in accordance with the accounting standards for income taxes, which require financial statement reporting of the expected future tax consequences of uncertain tax reporting positions on the presumption that all concerned tax authorities possess full knowledge of those reporting positions, as well as all of the pertinent facts and circumstances, but prohibit any discounting of unrecognized tax benefits associated with those reporting positions for the time value of money.

The following is a summary of the activity of the Company's unrecognized tax benefits for the six months ended June 28, 2014 and June 29, 2013 (in thousands):

   June 28, 2014 June 29, 2013
Balance at the beginning of the period $ 24,716 $ 64,390
 Changes resulting from completion of tax examinations   -   (35,279)
 Other changes in uncertain tax benefits   (1,952)   (1,670)
Balance at the end of the period $ 22,764 $ 27,441

With limited exceptions, the Company is no longer subject to examinations in significant jurisdictions for the years ended on or before December 31, 2009. However, carryforward attributes that were generated in years beginning on or before January 1, 2010 may still be adjusted upon examination by tax authorities if the attributes are utilized. The Company continuously monitors the lapsing of statutes of limitations on potential tax assessments for related changes in the measurement of unrecognized tax benefits, related net interest and penalties, and deferred tax assets and liabilities.

 

During the six months ended June 29, 2013, the Company recorded a $31 million reduction in the measurement of its unrecognized tax benefits due to the completion of certain tax audit examinations, which reduced the provision for income taxes and increased net income for the six months ended June 29, 2013 by $31 million. As of June 28, 2014, the Company expects to record additional reductions in the measurement of its unrecognized tax benefits and related net interest and penalties of approximately $6 million within the next twelve months due to the lapsing of statutes of limitations on potential tax assessments. The Company does not expect to record any other material reductions in the measurement of its unrecognized tax benefits within the next twelve months.